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A makes a lifetime settlement ('the A settlement') under which the settled funds are directed to be held on trust for B for life with remainder to C absolutely.

C then makes a settlement ('the C settlement'), of his reversionary interest under the A settlement. C's reversionary interest is excluded property and the making of the C settlement does not give rise to a transfer of value.

The trusts of the C settlement are as follows. A one-half undivided share of the interest is held on trust for M for life with remainder to N. The other half share is held on conventional discretionary trusts.

Assuming A's settlement is made before 22 March 2006

If A's settlement is made after 26 March 1974 and before 22 March 2006 and B subsequently dies before 22 March 2006 the position is as detailed below.

While B is living:

1. Ìý

   (a)ÌýÌýÌýÌý The termination of M's interest in possession under the C settlement would not be a transfer of value, whether it occurred during M's lifetime or on M's