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The solicitors had advised on a trust settlement. As a result of allegedly negligent advice the settlor had retained a residual interest in the settled property exposing the estate to inheritance tax that could otherwise have been avoided. A claim by the residuary beneficiary of the estate would not be struck out because of the Court of Appeal decision in Daniels v Thompson. It was arguable that the residual beneficiary was owed a duty of care even where he was not identified at the time of the advice given.
For Inheritance tax advice in respect of assets held in Spain you can read about this here.