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HMRC internal manual

Capital Gains Manual

Conventional but bare trusts: powers of appointment held by beneficiary

In certain cases a person may have a life interest and also a general power of appointment (to give) by deed or will. This means he or she can execute a deed giving the property to anyone he or she chooses or state in his or her will exactly whom the property goes to and on what conditions. The simple test is whether the beneficiary has all the interests under the settlement, without exercising the power of appointment.