Hello and welcome everybody. My name's Safta Mahmoud and I'm pleased to welcome you to today's session through data law. This is the course on introduction to wills and drafting. As of june 2020 to this to this session three And the final session of this three part series. Looking at the area surrounding will drafting and wills in terms of law practice and procedure. So you'll recall that in the first session, I spent a fair bit of time going through with you. The benefits of making wills what property passes independently of the will and intestine provisions. We looked at the position would take instructions, requirements for valid will in terms of capacity intention formalities and alterations. In the last session. You remember I spent some time going through with you. D positions surrounding revocation of the will, the structure of the will, what specific clauses need to be inserted within the will uh the types of gifts, general specific demonstrative gifts, non beneficial provisions in particular and beneficial provisions and all sort of positions running substitution, all gifts insofar as that's concerned. And then we also spent some time going through the area of intestine. See what I'm going to be doing today then is looking at the remainder of this course, we'll be spending some time going through with you the positions around the inheritance provisions for family independence Act of 75 claims that may be brought under that. And I'll spend some time looking at post death variations disclaimers and finally some elements looking at the impact of inheritance tax when one is looking at world drafting And as always, I'm looking at the law and technology and crown copyright and also the Dfe S corporate author. And we're looking at the laws of June 2022. So as you remember in the last session, I spent some time going through with you do position with intestine and you remember I discussed the position who benefits under in testes. E so somebody was to die either having had left no will at all or no valid will and then went through with you who would benefit in that regard. And we looked at the position with the spouse, the civil partner. The issue uh and Andy various other categories of persons under the statutory trusts. But the persons who do not benefit on the testes. E therefore are for example, cohabit ease former cohabit ease child of some child who is treated as a child of a disease, for example. And other people who may have been maintained by the deceased immediately before their death, maybe an old leaf family member, for example. So in such cases, you may find that such categories of persons and indeed limited other situations, the person may wish to them potentially bring a claim under the inheritance provisions for family Independence Act of 1975. So this is where this provision comes in. And what we need to ask ourselves firstly is if we are instructed by any such person to apply to bring a claim, then this act doesn't apply to lifetime gifts unless they've been made with intention of defeating the polls, death claim. And the claim cannot be made under this act until death has of course occurred. Of the of the person against whom they're bringing the action. And the person who's bringing the action needs to do so on the basis that they are saying that the disposition of the disease estate affected by the willow intestines, c or combination of under the willow in testis is such that either no reasonable provision was made for provisions or no provisions at all, nor reasonable provision was made for the applicant at all. So it's got to be either of these, So to be able to bring a claim under the 75 act, you would need to show that all of these conditions are met. Firstly, deceased must have died domiciled in England Wales. Okay, so they must have seen England Wales at the point of death as their permanent place of residence. That's the first requirement. So the intention of not only not only residing in England Wales, but actually singing in Wales as their permanent place of residence. Secondly, the applicant must have local standout. So there must be in one of the categories of persons who can bring a claim and we'll look at the various categories of applicants shortly. And thirdly, they need to bring their claim within six months of the grant, unless the court gave permission for them to apply outside that period. Okay. And the only grant for a claim is whereby the applicant is stating that the deceased I'd left them nothing in the will or intestine provision made no provision for them. What they did leave was insufficient. So it wasn't reasonable in the circumstances In terms of who then has local standards. So who can actually bring an action? And this is where paragraph 15 schedule for Civil Partnership Act 2004 extended what we mean to the persons in the first category in terms of spouses to also include civil partners. So this is where you've got a spouse or civil partner who come bring a claim. And then you've also got section 11 B. Which is a former spouse or former civil partner. Disease who has not yet remarried or former civil partner is not enter into a further civil partnership. So this could be where say you got a husband and wife who were married, then they divorced the final order. The decree absolute finance for the marriage. And then said a former husband passed away. They never did resolve the finances. So that could be in that situation or the other could be where they die, said the husband and wife and married. They don't divorce, husband dies, wife. Then we need to bring a claim on that basis. So that's possible as well. Of course. Uh And then the other is section 11 B. A. Which is where by the person is living in the same household as husband and wife for same sex couples will effectively cohabit. E. So this was introduced by section two of the law reform succession act of 1995. So this is where they've been living together for a period of at least two years, two years immediately preceding the death of the deceased in those circumstances. And they were living in the household as a couple ideas as as a couple as husband and wife or say as the same sex couple, civil partners or otherwise, but they did not commit to marriage or civil partnership. So effectively cohabiting for two years and more immediately before the death of the deceased. And the other situation is how this is different to section 11 E that would take you through shortly is here. You do not need to show that the person was maintained by the deceased immediately before the deaths. As long as they were cohabiting for two years and more than this, satisfied that contingency. So what's the position that if the deceased did not immediately cohabit before his death due to for example becoming ill and becoming hospitalized. For example, this is where case like the bomb are quite useful because in that particular case, the court did say that one has to ask whether the arrangement for for cohabitation was in fact still in place at the date of death. If it was then it would nonetheless satisfied the requirement, even if disease was hospitalized for a period of time before their death. So as long as the arrangement continued, even though they obviously were at the hospital, they were ill. There may have been there for some time, the rearrangement of relationship continued and therefore that's what's important in this regard. Then he got section 11 C. Which is where the application is by chart of the deceased and the child here includes a legitimate child and illegitimate Children as well as well as Children who may well have been adopted by the deceased and Children conceived were not yet born at the date of death of the deceased. But this category, section 11 C. Does not include a step child. Okay. But they will be included in the next category which I'll take you through section 11 D in terms of a child treat as a child of the deceased. Now when Children are applying there is no age limit for them applying. So even though there may be over 18 and therefore an adult, they can still applying to this provision and in fact, you'll find in practice, many of the applications will be brought by adult Children in that regard. Okay. And often the person may be claiming that they have a moral claim where they may say that there may be under disability uh and they were dependent on their on their parents or maybe they may have worked in the family business, for example on low wage when the expectation of being provided for in that regard. And that's where they may wish to them potentially bring your claim on that basis. Then he got like say Section 11D which is the person who was treated as a child of the family. So this would include for example, step Children where they were treated as a child of the family as well as any other child. Now, as I mentioned earlier, stepchildren would not therefore benefit on the intestines the as I mentioned earlier. So this is why this particular provision and the act is particularly relevant. Four step Children for example, or any other Children who were not biological or adopted Children of the disease, but who were treated as a child and family. And this is where by uh there were amendments brought about by the inheritance provisions for funding dependence act by scheduled to inheritance and trustee powers act. And a child is treated as a child. And family body sees whereby the child at any time stood in the road whereby deceased rather 10 times during the role of a parent. Okay, so therefore it's not the case that one I should show a person treated the child or the family in that regard. Okay then the other category, Section 11E is where the person was maintained by the deceased. So this would be covering situations where somebody was immediately before the death of deceased, maintained either wholly or partially by the deceased. So this could cover various types of people, not just people who are cohabiting in these circumstances. And this is where by maintenance can cover the disease. Having made a substantial contribution in money or money's worth towards the need needs of the applicant has been shown that the disease was not receiving full and valuable consideration for maintain the applicant and this arrangement must have continued until disease died. So in practice, this has been used in situations whereby, say, the the claim is actually being brought by, say, the elderly father. So say the elderly father is bringing a claim against the estate of his of his late son who has passed away, but his son was actually looking after him before his death. So let's say it's a case where the son passed away, say he was in his fifties, for example, has passed away, he was looking after his elderly father and um the the sun dies the only father, the rest of the family and are now and not really supporting the father and therefore he feels that really he was being maintained by his son without full and valuable consideration. So he brings a claim under the estate on that basis. So he may do so under section 11 E. That's where that comes in. Now, what do you mean then? Buy immediately before the death? And this is where the case of the bomber comes in, then which says that it's not just a simple looking at position immediately before death. You need to look at the so called normal habitual state of the relationship in that regard. So what what's the arrangement like? So somebody who's been nursed through terminal illness for example. But in the last few weeks they were hospitalized. They can satisfy that contingency. But if the situation say you're applying under Section 11 B. A. On the basis they were cohabiting for two years and more immediately before the death of the deceased. And let's say they separated a few weeks before the death of the deceased. And it cannot be established that there was a chance of reconciliation. That it may be difficult to then be able to show that they were maintained by the disease immediate before the death or they were cohabiting immediately before the death. So you do have to look at what the position was in that regard. Now, the next bit then is if you do come under one of these various categories, you don't have to show that if you have demonstrated in local standards. So you do come within one of the applicants vacations. In terms of your one of the applicants, you then need to be able to show that you were left no or no reasonable financial provision. So what do you mean by being maintained? And this is where this did change as a result of Schedule three of the inheritance trust in the powers Act of 2014. So that when one is applying as a person being maintained by the deceased, they are treated as being maintained by the deceased, either wholly or partially on the deceased. Was making a substantial contribution in money or money's worth towards a reasonable needs of that person or the contribution made for for valuable consideration. So as long as it's uh substantial contribution of money and money's worth, that's what you're looking at. Now, there's two types of standards. So when somebody does apply, there's two types of standard that one will be looking at. You'll be if you're applying as a spouse or surviving spouse or former spouse or as a civil partner of former civil partner, then you'll be applying to the spouse or civil partner. Standard, which is, you'll be dividing, you'll be seeking a claim on the basis of what potentially would have been awarded had the result of finances following the divorce or separation or the separation proceedings and therefore it's on a high standard. But in all other cases, the maintained standing applies, which is really looking to see what amount the person was being maintained by and therefore looking to see whether that's possible being continued. So the factors that the court will take into account in deciding what award, if anything make us attack within section three. Subsection five of the act, and the court will take into account the facts known as at the date of the hearing. So they'll take into account the position at the date of the hearing, as opposed to date of death of the deceased. And there is therefore a number of factors which the court will then way up in deciding what order if they need to make. So they take into account of financial resources and needs of the applicants. So they'll need to take into account matters such as the earning capacity of the applicant. Uh What's the position with any pension entitlements, Social Security benefits that they may be entitled to order. May already be claiming. What's the earning capacity? What resources do they have court take into account? The financial is also needs, or the beneficiaries under will. So, you're not just looking at the financial business position of the applicant, you're looking at the financial position of the other beneficiaries under the willow in Testes E as well, to see what they have, what they need and if the needs of the beneficiaries are significant, then you may well find that the applications and under the 75 Act may well fail. It's important to bear that in mind in that regard, the court also take into account the obligations and responsibilities that the deceased or towards the applicant or beneficiaries under the testis is. So that's where your responsibilities comes into play. You take into account the size of the nature of the estate of disease. So if there is insufficient as it is there that you may find there's less chance of the application being successful. You're looking at any physical mental disability of the applicant or beneficiary in the will and test that can then have a bearing on this as well of course. So you're looking at that physical or mental disability and then any other matter including conduct of the applicant or of any other person in that regard. So this is where You can then take into account that section two of the civil evidence sector 1968 which does allow the court to admit written or verbal statements as to why the deceased made little known provision for the applicants. So this is where you remember the last session I discussed with the U. D. benefit of having separate lateral wishes which is kept separate the will set and why the deceased that the test data decides to leave nothing or very little to certain family members. They may even do a witness summary or statement which then can be used evidentially at any 1975 and claim for example. So even that can be taken into account and it is important for test data then who wishes to exclude a potential beneficiary then to make a statement as this statement can then be taken into account to set out why that applicant potential applicants should not be allowed to benefit in these circumstances. So that's the thinking behind that. Then there are particular guidelines as to particular classes of applicants. There's various guidelines for each different type of applicants in that regard. And if, for example, the application is by the surviving spouse or surviving civil partner, for example. And the court will take into account the age of the applicant and duration of the marriage or civil partnership. So if they've been married for some time and now divorced and the finances were never resolved, then that potentially can increase need and dependency and therefore potentially make the argument for larger contribution there. You also look at the contribution by the applicant, the welfare of the family, so how they contribute towards the family in terms of being a homemaker. Otherwise, for example, the court may also take into account what the applicant may reasonably have expected to receive if on the day when the disease actually died of marriage or civil partnership dealt with this instead of being terminated by death. So what they would have, God had been terminated by divorce, for example, and that's why the amount that they would be eligible is based on the spouse standard, as opposed to the maintenance standards. Okay, so looking at those factors there, in terms of spouses, former spouses applying in that regard, The court will take into account the factors under Section three. Subsection 2. So the age of the applicant, duration of the marriage and the contributions. As we're saying there in terms of the other applicants. You're looking at persons living in the same household as a husband and a wife for civil partners. So this could be where you've got two more people and who were cohabiting. So here you're looking at the age of the applicant, length of time in which to live together as husband and wife, for example, And also the contribution towards the welfare of the family. So you can see those factors are particularly relevant here. In terms of applications by the child of the deceased. Charter, deceased member would would then incorporate a biological or adopted child with a legitimate or illegitimate. And you do need to look to see whether or not the deceased had assumed the responsibility for the maintenance of the applicant. And if so, to what extent and they will consider the liability of any person to maintain the applicant. So this is where there was a significant case a few years ago and that some of you will remember it was the case of Ireland and medicine and others. And just going to go through this case with you, starting with the Court of Appeal decision. And then ultimately, what happened in the Supreme Court. And this was a case then which involved an application for maintenance pursuit. The 1975 act brought by the adult child of the deceased. And what happened is in August 2007, the district judge had awarded £50,000 in favor of the adult child of the disease MS Islet And 2014 mrs. Justice Parker dismissed the appeal from the lower court order that the daughter did claim. She said that she had bought her claim under the 75 Act against the estate of her late mother, Melita Jackson. So this was her mother who she was bringing the claim against. And what happened is this? The deceased had left an estate which was valued at around £486,000. She she had left a will, in which subject to a legacy of £5,000 in favor of the BBC Benevolent Fund. She left the rest of the estate divided between various charities, none of which she had any significant legions towards. And she had a daughter who was the only child that had been estranged for some 26 years And the daughter was aware that her mother had intended to leave her nothing the estate at all. And in fact, like say, other than this, £5,000, the rest was given to these various charities. So did the will make uh will not make a reasonable provision for the daughter. With a paragraph three. Her ladyship did say that reasonable financial provisions can only be made For the daughter by providing her with a son that she required to buy a house. She needed amount of some 100 86,000 lb, and the court did order that as well as the cost of purchase, and also a capital sum of £20,000 to provide this amount. And by awarding these amounts, it would still preserve the state benefits that she was getting and she would continue to be entitled to. And here this is where the court then looked at the law. So they took into account in 1975 Act, the daughter was applying will be an adult here as a child of the deceased and the court satisfied that the will had made no provision for the daughter. And the court did say that Section one, subsection two of the 1975 Act does specifically say that the court needs to take into account all the circumstances and here, the court said that uh in these types of cases, these cases are limited to maintenance. Whereas for spouses or civil partners cases such as this are not limited in that case and therefore you can even apply the spouse standard. So the court did say that the claimant's claim was limited to maintenance and the court referred to some of the older authorities. There was a case of recover entry a few years ago in 1979, where you're looking at providing towards well being, but in looking at maintenance, the court said, this should be really looked at in terms of assisting to discharge the cost of daily living, whatever standard of living was appropriate for them. And this could be provided for this maintenance. If the call was to order, it could be made available by way of maybe ordering income payments, payment of a lump sum, enabling her to buy a house, for example. And what factors will the court then actually take into account in deciding what water, if any, to make. And in particular, the court said the factors were contained within section three subsection one of these, 1975. So we're claim is broad. Then the court would have to take into account these factors under section three. Subsection one. And these were the factors and many of you will be familiar with these. So you can see the court will take into account of financial resources, financial needs of the applicant. Financial resource, and financial needs which any other applicant may or may hassled may have in the foreseeable future. Then you look look at the resources and financial needs of the beneficiaries, the obligations or responsibilities which the disease have towards the applicant and any other beneficiaries. You can look at the size of the nature of the estate, any physical or mental disability, And also any other matter including conduct. So you can see these are the factors which are all weighed up in deciding what order is failing to make and that evidence, as I mentioned, has to be considered a date of the hearing pursuant to section three subsection five. And the call is therefore, take into account the claimant selling capacity and obligations. Now, why did the mother leave her daughter? Nothing in the world? Well, the court did say a paragraph 18 her ladyship said that the main reason was as that they were strange. My daughter was the only child of Mr and mrs Jackson. Mr Jackson had been killed in an accident at work three months before his daughter was born and the employed made a substantial payment to Mrs Jackson, which she used to pay off the mortgage and they had tried to attempt a reconciliation. But sadly it just didn't work or which failed. And like so daughter, the mother in leaving a substantial part of her state to these charities. She had very little connection with them During her lifetime. So, the court had awarded an amount of £143,000 which was the cost of acquiring the property as well as expensive property and further sum of £20,000 to enable her to obtain this additional equipment income to supplement her state benefits in that regard. So, that was granted. But the charities did in fact appeal to the Supreme Court. And this is where the Supreme Court unanimously did allowed the appeal, but they reinstated the original water £50,000. Uh And this is where the Supreme Court still therefore allowed the daughter to benefit, but not to the amount that the court appeal had allowed for. And I did say that we are in this rather unsatisfactory state of the present law because it provides no guidance as to factors to take into account in deciding whether an adult child is deserving or undeserving of reasonable maintenance. And the Supreme Court did say That the Law Commission did not reconsider the fundamental principles online such claims when the last dealt with this area in 2011. So you can see this is obviously a significant area which therefore needs to be looked at further going forward. So that's the islet decision in that regard sort of Supreme Court and upheld the previous award of £50,000. Now, if somebody is going to be bringing a claim under 75, can they bring a claim before the grant of representation has been granted? And the simple answer is this charger two of the access that nothing prevents the making of an application before the grant is first taken out. But a person can apply after six months after grant was issued but need leave. So even though you can apply beforehand, what normally happens is a person will do what's called a standing search at a private registry. That search would enable him to say as to whether granted granted representation has been issued or not and in the preceding 12 months or not and that then enables them to know that they have six months following that grant to bring a claim and it can apply for leave if they got good reason to apply outside a six-month period, if needs be. Now, if the person does bring a claim and they are successful in courts, powers are such that they can make a number of orders. They can order income payments by where periodical payments for any period of time. They can order a lump sum payment if needs be transfer property, the settlement of property and the acquisition of property. So in the island case that I mentioned, you can see the court awarded the, the lump sum and also the uh, the position with uh, the transfer as well. So that's the thinking behind that. And these orders, once they are made, the orders are deemed effective from the date of death and therefore an order made potential, therefore result in other beneficiaries, either receiving less under the will or intestine sea routes in those circumstances. And this is why it's very, very important for some of you who may advise on private client. And some of you may also do matrimonial cases that when you've got parties who are divorcing or dissolving their civil partnership is very important to have a financial consent order drawn up so that once they have resolved the finances denies of them can then bring a claim against each other, not only during their lifetime, but indeed after death under 75 act. So this is where we would have these, what's known as a clean break clauses to prevent The party's them from bringing claims against each other in the future. One leading case on that was a case of Wyatt and Vince in 2015, a few years ago, this was one whereby the couple had been married. It was a very short married only for a few years, then they divorced, there was a child involved. Uh neither of them resolved the finances at that stage and in fact, it was only until about 22 years later that the former wife decided to bring a financial claim with a view to resolving the financial issues between her and her former husband. So she lodged the application and her husband applied to strike out on on the rule of 4.4. The family procedures of 2010 on the basis. He said, Look, she hasn't got her uh any merit in pursuing her application. But in fact, the court dismissed her husband's application and they did order him to paint from periodical payments matter, went to court appeal. They set aside the orders and struck out the wife's financial application, but she hadn't appealed to the Supreme Court. In fact, uh the court did say that she was living in a property in a poor state of repair. Her husband had Over the many years previously set up the electricity group limited, which provided green energy green electricity to about 70,000 homes. His business was worth about 57 million. And he was living with his second wife and child. And the court said that even though there was a claim brought some 22 years later, we do have a duty under section 25 of the matrimonial causes in 1973 to look at all the factors looking at her needs and these needs. And an application strikeout was not applicable. So it did allow the application to continue. And in fact in white convinced 2016 the two were neither of them were able to settle. Even though the matter was listed for hearing what's called the F. D. R. The financial dispute resolution here and to try to resolve matters. They couldn't Until eventually they managed to settle by whoever consent order whereby the former husband paid a former wife an amount of £300,000 full and final segment. So you can see it's very, very important to have these financial consent orders made to really prevent these potential Claims have been brought under a 75 act in the future. That's the thinking behind it. And the court did in fact approved that order as well in that regard. Right, just for the last part of today and I just want to spend a little bit of time in going through with you to position with post death variations and disclaimers. And then some elements on inheritance tax planning. So sometimes you find that when gifts are left to beneficiaries, they may decide not to accept the inheritance under the long tested through. So this is where they can effectively disclaim. Disclaim is just that this is where they refuse to accept what they may be entitled to. And if that's the case, if somebody disclaims then that property will pass as if the beneficiary had predeceased intestate intestate. So therefore, if it's a monetary gift in the world and it falls into residue if it was residue and that potentially come forward into partial intestine. So that's if somebody disclaims in that regard. Okay, But a disclaimer is different to a variation in that with a disclaimer, the beneficiary has no control over the destination of the disclaimed property. So if it falls into parchment test is he didn't have a say over that. This is where variation is different. And unlike a disclaimer, this isn't really just saying, look, I don't want this item, they also providing a direction as to who they feel that the perverse personal representative should be transferring that to. So the original beneficiary therefore controls the ultimate destination of the property. So this could be where Sadie uncle who has left a gift in the world by his brother says, look, I wish to vary. So I don't want to wish to take it. But I'm asking the person representative to transfer this gift to say, the deceased Children, for example. So that's where the variation can come in in that regard and sometimes they can be useful in relation to tax planning as well. Now, therefore, in terms of inheritance tax planning, this is where when somebody has passed away, we need to then ascertain what amount of tax, if any may be payable on death, inheritance taxes payable. Chargeable as if the deceased had immediately before his or her death made a transfer value of an amount equivalent to the taxable amount. And and the taxable estate means the aggregate of all property which the deceased was beneficially entitled. So when you're dealing with inheritance tax, you need to look at this in terms of five stages in calculating what amount of inheritance tax, if any is parable, which is firstly identified their taxable estate. You've then got to get it valued. You then apply the relevant exemptions and release, and then you calculate on what's left the amount to take into account and transfers they're made in the previous seven years. So first and foremost, then look at what property then passes under willing testes. E. So look at that and look at what that is to then see what potentially properties to see what needs to then get valued. So then you get that valued and then this is where you can apply the exemptions and there's various exemptions applicable on death and it depends on the identity of beneficiaries. So, for example, is what's known as a spouse exemption, which means that if any property which is including the estate tax purposes passes to the deceased spouse or civil partner, regardless of whether it was in the willow protesters who was a survivorship spouse exemption applies. And therefore that would make that that amount of property exempt and therefore it wouldn't need to be brought into the calculation. And similarly charity exemption uh property which forms part of disease. A state which passed the charity may be exempt from H. D. Depends on the amount of these. But that that can also be exempt once you've dealt with any exemptions that apply any release and what these can do is actually reduced the value of property to which the tax would be chargeable. And the two main reliefs that some of you will be familiar with is what's called the B. P. R. The business property relief which is relevant. Business property may be reduced by 50% 100% according to category. And then you've got what's called a pr agricultural property relief which is where you can reduce the amount uh if it's a if it's agricultural property relief And once you've done that then you would then apply on the net estate. What's left uh the inheritance tax threshold. And what's left then after that is then going to be charged with about 40%. Okay, but it's important as I mentioned in the previous session to look at any lifetime gifts that were made in the previous seven years because they may have to take into account as well. And there are a few other exemptions which are worthy of note. So for example, from nine October 2007, you have what's called the unused annual rate band on a person's death, which is transferable. So this is particularly helpful for spouses and civil partners. So that if say you've got say the husband who died say 10 years ago and he left everything to his wife and now she's died 10 years later. She's leaving everything to her Children. And she's got her own band of £325,000. But because her late husband left everything to her, he didn't need to dip into his residence in the band because he's left everything to her. And hence his powers exemption applied. So in fact to benefit the Children, you can use not only their moms, 3 to 5 band, but you can also add on their late their fathers uh near a band of 3 to 5 as well because that had been unused. So you've actually got 6 50 as a net amount before you need to see the taxes payable. So this is very useful. And finally, in addition to that, there's also what's known as a residence near eight bandits became available on the sixth of april 2017. So if an example, I've just given you say the father had a home or share of it that he had lived in at some stage during his life and he has then left it to his Children to his direct descendants. So his Children grandchildren, great grandchildren or a share of it. And as long as the value of the estate is worth no more than two million. If it is, then the use of this residents knew a band is going to be tapered or withdrawn altogether. And if he's downsized to a less valuable home or sold away after seventh of july 2015, you can use that. And what happens is if this year or this house was given to his direct descendants, whether to the willing testes, e otherwise, uh, then if the residents knew a band is used, it can actually take that those figures out of the pot and therefore potentially reduce the amount of the size of the estate and therefore attention is less or no tax payable. Okay, so it's worth noting that as well, which is a really useful relief. Right? So there we are. So that brings this session to an end. In fact, it brings the complete course to an end. So you can see we've spent a fair bit of time. They're looking at the position with wheels in terms of drafting and also in relation to position with some of the aspects of how wheels operate and putting these together as well. And I thank you very much indeed for listening. I hope that's been a useful session for you. And I would suggest that you have a mother, look through the sessions just to try and pull it all together. So thank you very much indeed. And I wish you well for the future. Thank you very much. Take care. Bye for now.