Weekend at Bernie’s Farm – Act Two

In the first Act we saw that mysterious forces might have been at work to bump off Bernie. The boys hatch a cunning plan to preserve their inheritance whilst, well, preserving Uncle Bernie. Sir David Attenborough explained the slated APR and BPR changes due to take effect from April 2026 from a balloon over the rainforest.

Now, the plot thickens…

ACT TWO

[I agree with you, having read the first Act, that the plan all seems a bit elaborate to save 50% IHT on the value of the farm that exceeds £1m. But then we wouldn’t have this marvellous caper… and let’s face it, it’s not the biggest weakness in the plot.

For instance, there are also some real biological issues here.

How long before Uncle Bernie gets a bit pongy?

Even if they put him in the chest freezer overnight.

Clearly, when they try and get Bernie’s death certificate post-election 2029… it probably isn’t going to take Dr Nikki from the Lyle Centre to determine he died a good few years ago…

And finally, what about the flies? We’re on a farm for God’s sake!?

…but it it was good enough for 80s Hollywood…]

Anyway.

The plan is afoot.

Almost immediately, the guests start entering for Bernie’s barn dance. There is little time to contemplate their decision any further.

// BARN DANCE //

It seems from the script that, about this time, the town holds a barn dance on the farm each year. [It says hoedown. So, this script could have been misplaced by a BIG Hollywood writer).

It’s held in one of Bernie’s barns, which is decked with bunting, hay bales and fairy lights. Music is playing and locals are do-si-do-ing. [I don’t know what that is, but it seems to be relevant to the ‘plot’.]

Bernie, is lashed upright on a chair, which bounces rhythmically due to the music and dancing of the guests. Of course, everyone knows that this is all it takes to convince party guests that Bernie remains very much alive and kicking.

Just then, the doors burst open. In strides a ruddy-faced farmer in a wax jacket, cheeks aglow from a day on the tractor… or perhaps the local cider.

He climbs onto a hay bale like a be-wax-jacketed prophet on the mount.

Farmer (shouting over the music):

“Listen up! They told us these IHT reforms would be harmless.

But new figures say nearly 200,000 jobs are at risk across farming and family businesses!

Two hundred thousand!”

The music falters. A tractor backfires outside. The crowd gasps.

Farmer (voice rising):

““And they reckon it’ll wipe almost £15 billion off the economy.

Yet they still say it’s only a few hundred estates affected. Pah! That’s hogwash, and I’m told the hogs agree!”

On cue, a piglet escapes from a pen at the back of the barn and charges between dancers.

Right at that moment, Bernie is swung into the do-si-do… colliding with, and at the same time, subjugating the piglet….

Villager (applauding): “Look at Bernie! Still fighting for our livelihoods! What a man!”

The barn erupts in cheers. Bernie is limply hoisted aloft like a folk hero, hay in his hair and the rope from his former shackles dangling from his waist.

Beyond the dance floor, Rachel from Horticulture (aka, master of disguise, Agent Reeves) is judging the “giant vegetable competition”.

She had just awarded the prize to a woman who had grown a leviathan of a lettuce. “Reminds me of Liz Truss” Reeves said witheringly as she pinned the gold rosette to its grower.

However, looking up at the scene in front of her anew, Bernie, to her susrpise, appears to be very much alive. She outwardly seethes.

Agent Reeves (to herself): “Jobs lost or not, one way or another, Bernie’s Farm is going to the Treasury…”

Reeve’s picks up the nearest thing to hand, the silver rosette winning marrow, and hurls it, with surprising strength, at Bernie. It clomps him on the side of the head. A sickening blow and he crumples to the ground, evidently, stone dead.

She scuttles off with a satisfied grin on her face.

Yes, indeed. Someone else has their sights on the farm.

It is the Treasury’s new, secret Taxing (your) Wealth Acceleration Team.

[In preparation, they had some cool jackets made up with the initials on the back to look like the US SWAT team… Fortunately, as they all usually work from home, the scandal of being photographed in these garments has not yet hit the press.]

So, who are these TWATs?

Well, back in the early 2010s the government introduced Accelerated Payment Notices (“APN”) which meant any disputed tax (in tax avoidance schemes) was put into the hands of HMRC pending resolution of disputes.

This was seen as a jolly good idea.

A natural extension was to examine ways of further accelerating the collection of tax receipts more generally.

In the absence of a wealth tax, which everyone agreed was daft and unworkable, a compromise was reached in secret at the Labour Party’s 2025 conference.

The idea was that large estates would be identified… and the beneficial owners would be encouraged to make the transfer of value of their estate more quickly.

And by encouraged, well… errr… I mean more kind of euthanised.

[Euthanised is such a strong word. Can anyone suggest a euphemism for euthanasia? (Note to self – that’s a good title for a 90s grunge album).]

After all, staying alive is an egregiously blatant piece of IHT avoidance.

So, that’s where the TWATs come in.

Always one to lead from the front, Rachel Reeves who was still chancellor [perhaps the biggest leap of faith in this plot, I know] decided to take to the field.

In this case, quite literally.

One Monday morning, the file of Bernie arrived on her desk.

So, as you may have guessed, dear reader, we originally joined this story just after Head TWAT Agent Reeves had paid Uncle Bernie a visit and delivered HMRC’s formal “Notice”… in writing… and also in a syringe.

In fact, and you may have guessed this too, the helmet headed HBOS compliance lookalikey the boys passed on their way to Bernie’s was Reeves herself. As we know, she is a master of disguise – whether physically, especially through her stunning ability to create new name badges for any occasion, and developing a new identies for herself through, say, a fictitious CV or two.

[I appreciate this is a bit of a jumble. But it is clearly a work in process. I am also not sure all the pages are in the right order.

But I’ll try and get back to the plan.]

“Bernie, what are you doing down there. What a character! Always hiding and playing practical jokes. Get up here you scamp”. Larry and Richard haul Bernie back to his feet.

…

Fast forward to the next morning and Larry and Richard have reviewed Bernie’s calendar.

He was meant to do a photo call at the local farmer’s market.

“Right, we need to get him up to the market” Larry impresses.

[The writer has then, in heavy pen, sets out the THE TRACTOR SCENE in bold capital letters and asterisks. He obviously likes this bit but hasn’t gone into much detail. I think it’s a bit of a visual joke.]

Anyway, from the notes and crude doodles it appears that Bernie is propped up between them in the cabin of the John Deere tractor [judging by the £££ scribbled in red, the writer is a bit too overly focused on product placement, if you ask me.]

Again, they’ve rigged up Bernie’s arms so they can make him wave like some kind of macabre marionette.

They pass locals who shout banal things like:

“Great shindig, Bernie”

“Way to catch that hog, Bernie”

However, they also pass another local farmer who can be heard talking to his tax adviser about an old succession plan they’d been discussing.

It’s clear he was looking at transferring his assets to a trust for the next generation.

He seems to be lamenting that he was going to use APR and BPR as a Trojan horse to get the assets into trust… or he might have been simply trying to get his horse, Troy, into the trust – there was a lot going on and it was difficult to hear.

He looks anguished and stressed. It is clear he now feels he has missed the boat on this important succession plan.

The local farmer, straight to camera [as I say, the writer does like to ‘break the fourth wall, darling], and says “here’s Professor Brian Cox in his private observatory to explain trusts:”

PROFESSOR BRIAN COX CUTAWAY: “THE THREE TRUST EVENT HORIZONS”

Starfield dome above.

A Foucault pendulum swings.

A chalkboard with orbit diagrams sits beside a small table stacked with books…

COX (to camera, warm, wry):

“People tell me that trusts are like black holes.
They’re not… they’re even harder to understand.”

COX (walking to the chalkboard):

“Start simple. A trust separates legal ownership from beneficial ownership.
The trustees hold the legal title. Their name is on the metaphorical tin.

But the beneficiaries are the people enjoy the economic benefits of the trust. So, they can maybe enjoy the income whilst the metaphorical strings remain attached. Almost like a magnificent cosmic string (Cox grins knowingly at the camera)

That separation lets families plan for succession.

They can steward assets, protect vulnerable heirs, and pass wealth across generations. The Trustees retain control with the beneficiaries enjoying the economic fruits.”

COX (leans in):

“Okay, the director is telling me to stop D:Ream-ing, and get on to the IHT bit.

Generally speaking, and with some exceptions, once assets are in a trust then they are also outside of any person’s estate for IHT purposes.

But that’s not to say that the trust is some celestial body that escapes IHT altogether. Your tax problem does not disappear into some kind of gassy nebula, you know.

Instead, when it comes to IHT and trusts… because I’m quite clever… I like to think of there being three ‘event horizons’. At each of these horizons, the trust might have to pay up some IHT.

[He flips the board: three concentric rings appear.]

COX (counting on fingers):

“One: A potential charge when assets go in.

Large lifetime transfers… by ‘large’ I mean above the nil-rate band (think of the nil rate band as a fiscal radiation shield exempting up to £325k)… into most family trusts will result in an immediate IHT charge.

That charge is 20% of the excess value in the absence of any reliefs…and we’ll come to those reliefs in a moment.

Two: A potential charge every ten years (the periodic charge)

Up to a maximum of 6% on the trust’s value after taking into account various allowances and those helpful reliefs.

You might think of each trust having a ten year tax orbit. So, in that regard, a trust is a bit like Jupiter.

Three: When assets leave (the exit charge)

When the trustees appoint assets to a beneficiary… or as I like to think of it, the assets have reached escape velocity… there is a smaller, time-apportioned charge that applies when property leaves the trust. This is a maximum of 6%.

[As he speaks, the rings glow in turn: “Entry”, “Ten-Year”, “Exit”.]

COX (gesturing to a model tractor and a tiny factory on the table):

Agricultural Property Relief (APR) and Business Property Relief (BPR) can reduce, and, historically, have often entirely eliminated these charges.

Yes, many farming and trading businesses have qualified in full… on uncapped values… on such transfers and events. Making travel through the generational planning worm-hole friction free.

But as Sir David Attenborough has already told us from his hot air balloon, the government have decided to take out a chainsaw to the relief.

And the reduced availability of the relief applies when it comes to trusts too.

N:Ightmare.

COX (with a half-grin):

“Right, I’m being told we’re out of time… and I need to feed the cat.”

He pours food into a food bowl with the name “Schrödinger” on it.

“Here, kitty kitty.”

 [TBH – I thought it might have been a funnier touch to have Brian Cox from Succession explaining trusts… but then he’s a bit of a lefty, luvvie. So, he might be reluctant.]

Tune in shortly for the third and final act…