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HMRC internal manual

Inheritance Tax Manual

Has an election been made?: persons making the instrument

The election should have been signed by all the persons making the instrument of variation - that is, by all the persons who were necessary parties (IHTM35041) to it because their interests were adversely affected.  Notice purported to be given on their behalf by, for example their solicitors was not acceptable.

The personal representatives (IHTM35055) did not need to sign the election in that capacity (whether or not they were parties to the instrument) unless additional tax was due as a result of the variation and they held sufficient assets in their capacity as personal representatives to discharge that additional tax.