Can person disclaim part of inheritance?

murphaph

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Hi all,
Had a search but didn't find something covering our exact circumstances.

My father passed away (intestate) in Jan 2008. He left his wife (my mam) and my brother and I.

My mother extracted the grant etc. and has been acting as his personal representative since then as we had a court case to fight a and it was advised to wait until that was sorted before divvying up the property.

It's now coming round to time to start work on this and my mam is looking for ways to pass on as much as possible to us without the taxman getting his hands on any of it (legally, of course).

The estate comprises a dwelling house (land registry), where my mother and brother live and have lived for years and some mixed use property (1 derelict dwelling house and 3 commercial units, all on the same plot of land and all considered one legal entity in the registry of deeds),

Mam is happy to gift us the property while she is still alive etc. and knows the risks of this from her side. We have some questions (we'll have to get all this done through our solicitor/tax advisor anyway, but we want to educate ourselves in advance so we know what options are open to us).

The main question is, can my mam simply disclaim the entire commercial property aspect whilst still inheriting her 2/3 of the house she and my brother live in or does she have to discalim the whole lot? (main reason is that the thresholds have been cut drastically since my dad died-if we inherited from him we'd have thresholds of €521,208 each, if we inherit from mam now or later, it's 250k which could trigger CAT in our cases.)

My brother doesn't have anywhere else to live and I am doing ok, so I would be happy with him ultimately inheriting the house they both live in, ie, I'd be happy to disclaim my 1/6 share of that house. I was reading CAT10 from Revenue and it seems to suggest that my brother could inherit the entire house with no CAT liability (from my mother!), as my mother is over 65 and he helps her round the house. BUT it states that in order for this to happen, he must NOT have any beneficial interest in any dwelling house. Would this include the 1/6 beneficial interest (from dad) in the house he would inherit itself? ie, would he also need to disclaim his 1/6 of the house from dad and let mam inherit the house in full and leave it to him in full in her will?

Assuming this is possible, could mam also gift it to him before she dies (hopefully not for a long while yet, touch wood!) and have some covenant drawn up that would guarantee her the right to reside there indefinitely? (we want to reduce the amount of things we have to do when mam ultimately does pass away, assuming she goes before us, as we found the whole thing horrible to deal with after my father's death and we'd like as much "done and dusted" in advance. Dealing with this stuff in the wake of my mam's death will be very difficult again and we want to minimise it)

It's complicated and we will definitely not proceed with professional tax and legal advice but your thoughts are really welcome :)
 
Just a first reaction, which might help you re-cast your problem:

The interest you and your brother each have in the estate does not have to apply equally to each individual asset. For simplicity's sake, let us suppose that the house is worth €400k and the other property is worth €200k. Your 1/6 entitlement and your brother's could be satisfied by transferring the other property to you, while your mother's 2/3 interest could be satisfied by her getting the house.
 
OP., Sorry for your loss. As a point of note, and as your father passed away in 2008, the allowances you and your brother would inherit would be applicable to the time in passing. As he died intestate, a Tax accountant or reputable solicitor would be best placed to advise you on the best way to proceed.
 
Just a first reaction, which might help you re-cast your problem:

The interest you and your brother each have in the estate does not have to apply equally to each individual asset. For simplicity's sake, let us suppose that the house is worth €400k and the other property is worth €200k. Your 1/6 entitlement and your brother's could be satisfied by transferring the other property to you, while your mother's 2/3 interest could be satisfied by her getting the house.
Cheers guys. Mam doesn't actually want to get her full share, if it means we can minimise overall CAT liability for my brother and I.

She'd happily disclaim her share of the commercial property (was independently valued at 850k in 2008-though God knows how much it's worth now) so we could inherit this (more expensive) asset directly from dad and so fall under the 2008 threshold, which would mean no CAT liability for either of us.

If she inherited her 2/3 share now and then passed it on to us later, we'd probably have a CGT liablitity (depending on market value at the time) as the threshold for Parent->Child has been reduced quite dramatically in the past 4 years (now only 250k, was over 520k back then).

The house (possibly worth 200k max today) I would disclaim any interest in and the idea is that my brother would be able to inherit that completely without CAT liability as he fulfills the requirements (as far as I can see).

There's no doubt that we need and will seek a tax accountant (our solicitor is good but no tax expert) for this, but I'd like to discuss here first so I can have an idea of the options open to us. We also really want to provide security for mam (hence the idea of a permanent right to reside covenant) whilst reducing/eliminating the amount of this stuff we'd need to do when she passes. It was a shock when dad died and we weren't at all prepared, we'd like to avoid that again.
 
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