musing on putting a holiday home in the name of adult kids

saajan_12

silvercar said:

Grumpy_chap said:

silvercar said:

Just musing at this point.

We have a holiday home abroad that we are considering selling. I know CGT will be payable, here and abroad. If we do sell, we would then buy a holiday home in the UK to make travelling easier than having to fly abroad. 

We are early 60s with 2 adult children in their 30s who are already home owners.

To avoid future IHT (we live near London, so thanks to HPI and having bought young, our estate on 2nd death will be liable for IHT) I am thinking it would be sensible to buy the property in the name of our 2 children, so out of the IHT loop if we survive 7 years.

The property would be kept for the sole use of family, not rented out. Whether the ownership is in our name or our children's name, the property would be available for use by immediate family/ siblings/ niblings only with no rent changing hands.

Any disadvantages tax wise, in putting it in the names of adult children?

So, you will sell your holiday home overseas and pay all the taxes that arise.

This will provide you with a lump sum of cash and you wish to be able to pass that lump sum to your two children such that they benefit from the asset value and the potential IHT can be avoided assuming you survive 7 years.

Why not simply pass the children half of the cash value each, with no strings attached?  That way, the two children can make their own decisions as to what they wish to do with the cash value received to suit their own current and future priorities.

What appears to be proposed is to "gift" half the cash value to each of the children but with the reservation that the value has to be used to pay for half of a holiday home which will be made available to you and other family members for use for holidays without charge of any kind.
This is really sounding like a Gift with Reservation (GWR) so would fail to take the value out of your Estate for IHT purposes.

As you and both children are all home owners, second property stamp duty premium will apply on acquisition.

Second-property Council Tax will apply.

CGT will apply on disposal.  The only way to avoid CGT would be if the property is still owned by the (by then) deceased at time of death.

Who has priority in deciding who can take their holiday in the holiday cottage when?  What if the two children and their families and you all want the same October half term week?

What happens if the children divorce / split from their partners and the now-ex wants to claim the quarter value of the holiday cottage as part of the separation?  Would that require a forced sale?

What happens if the children ever need to claim means-tested benefits?  The share of equity in the holiday cottage would be considered as capital and most likely exclude eligibility for means-tested benefits.

Partner issues are a valid point, but if you worried too much about that, you would not help your adult children in the way you would like. At the end of the day, in accepting a gift from parents, the kids have to accept that if their relationship collapsed they would have the consequences, but we can't not give them anything in case they break up and their ex's end up with some of our money. Otherwise they wouldn't have got on the property ladder in the first place.

 

I agree with this in principle, that it shouldn't be a blocker to what you want to do with yoru money, but I think its very much worth worring / planning for. Eg get an agreement in place on what happens in divorce (you can't just say the partner gets nothing, but maybe the others could optionally buy them out but if not everyone agrees to sell). More so to make sure everyones thoughts are aligned and it doesn't become an argument later. 

silvercar said:

penners324 said:

So the kids will have to pay additional SDLT every time they want to buy a new house.

They will have to pay CGT if and it's sold.

It'll become part of their estate, so they would have split their share, in cash, if they get divorced.

It'll likely be seen as deprivation of assets if you go into a care home.

I thought deprivation of assets only kicked in if you showed any signs of needing care at the time of the gift?
In any case, we have sufficient for our care earmarked elsewhere.

Extra SDLT on moving PPR won't apply as they already have a PPR each that they can replace if they decide to move.

We'd be lumbered with CGT on sale, as would they; so that won't make a difference. Same as we'd be saddled with extra SDLT on purchase as would they.

No, the point is it'll presumably be sold one day (likely after your death). If in the kids names they'd pay CGT on the increase from today -> sale, while if in your name then there's 0 CGT from today -> your death date, albeit replaced by IHT. 
You're treating it as saving the whole IHT, but actually you're only saving part, the rest offsets the CGT saving. If you live a long time and hence there's a large gain racked up, the saving could become small. 

sheramber

silvercar said:

penners324 said:

So the kids will have to pay additional SDLT every time they want to buy a new house.

They will have to pay CGT if and it's sold.

It'll become part of their estate, so they would have split their share, in cash, if they get divorced.

It'll likely be seen as deprivation of assets if you go into a care home.

I thought deprivation of assets only kicked in if you showed any signs of needing care at the time of the gift?
In any case, we have sufficient for our care earmarked elsewhere.

Extra SDLT on moving PPR won't apply as they already have a PPR each that they can replace if they decide to move.

We'd be lumbered with CGT on sale, as would they; so that won't make a difference. Same as we'd be saddled with extra SDLT on purchase as would they.

Your  kids would have a much ;arger CGT bill as it would apply from current buying proce  until date of disp[osal.

If in your names the house would not incur CGT on  death, so thye would only be charged  from the value  at inheriting it.

You live another 20 years then no CGT on increase in value for that 20 years.

If it is in your kids names from date of purchase they are clobbered with that CGT charge that could have been avoided.

silvercar

sheramber said:

silvercar said:

penners324 said:

So the kids will have to pay additional SDLT every time they want to buy a new house.

They will have to pay CGT if and it's sold.

It'll become part of their estate, so they would have split their share, in cash, if they get divorced.

It'll likely be seen as deprivation of assets if you go into a care home.

I thought deprivation of assets only kicked in if you showed any signs of needing care at the time of the gift?
In any case, we have sufficient for our care earmarked elsewhere.

Extra SDLT on moving PPR won't apply as they already have a PPR each that they can replace if they decide to move.

We'd be lumbered with CGT on sale, as would they; so that won't make a difference. Same as we'd be saddled with extra SDLT on purchase as would they.

Your  kids would have a much ;arger CGT bill as it would apply from current buying proce  until date of disp[osal.

If in your names the house would not incur CGT on  death, so thye would only be charged  from the value  at inheriting it.

You live another 20 years then no CGT on increase in value for that 20 years.

If it is in your kids names from date of purchase they are clobbered with that CGT charge that could have been avoided.

We thought we may keep the abroad place until death, so avoiding CGT, but plans change and so we may now sell and take the hit. No guarantee we wouldn't sell before death and therefore have the CGT bill.

silvercar

saajan_12 said:

silvercar said:

Grumpy_chap said:

silvercar said:

Just musing at this point.

We have a holiday home abroad that we are considering selling. I know CGT will be payable, here and abroad. If we do sell, we would then buy a holiday home in the UK to make travelling easier than having to fly abroad. 

We are early 60s with 2 adult children in their 30s who are already home owners.

To avoid future IHT (we live near London, so thanks to HPI and having bought young, our estate on 2nd death will be liable for IHT) I am thinking it would be sensible to buy the property in the name of our 2 children, so out of the IHT loop if we survive 7 years.

The property would be kept for the sole use of family, not rented out. Whether the ownership is in our name or our children's name, the property would be available for use by immediate family/ siblings/ niblings only with no rent changing hands.

Any disadvantages tax wise, in putting it in the names of adult children?

So, you will sell your holiday home overseas and pay all the taxes that arise.

This will provide you with a lump sum of cash and you wish to be able to pass that lump sum to your two children such that they benefit from the asset value and the potential IHT can be avoided assuming you survive 7 years.

Why not simply pass the children half of the cash value each, with no strings attached?  That way, the two children can make their own decisions as to what they wish to do with the cash value received to suit their own current and future priorities.

What appears to be proposed is to "gift" half the cash value to each of the children but with the reservation that the value has to be used to pay for half of a holiday home which will be made available to you and other family members for use for holidays without charge of any kind.
This is really sounding like a Gift with Reservation (GWR) so would fail to take the value out of your Estate for IHT purposes.

As you and both children are all home owners, second property stamp duty premium will apply on acquisition.

Second-property Council Tax will apply.

CGT will apply on disposal.  The only way to avoid CGT would be if the property is still owned by the (by then) deceased at time of death.

Who has priority in deciding who can take their holiday in the holiday cottage when?  What if the two children and their families and you all want the same October half term week?

What happens if the children divorce / split from their partners and the now-ex wants to claim the quarter value of the holiday cottage as part of the separation?  Would that require a forced sale?

What happens if the children ever need to claim means-tested benefits?  The share of equity in the holiday cottage would be considered as capital and most likely exclude eligibility for means-tested benefits.

Partner issues are a valid point, but if you worried too much about that, you would not help your adult children in the way you would like. At the end of the day, in accepting a gift from parents, the kids have to accept that if their relationship collapsed they would have the consequences, but we can't not give them anything in case they break up and their ex's end up with some of our money. Otherwise they wouldn't have got on the property ladder in the first place.

 

I agree with this in principle, that it shouldn't be a blocker to what you want to do with yoru money, but I think its very much worth worring / planning for. Eg get an agreement in place on what happens in divorce (you can't just say the partner gets nothing, but maybe the others could optionally buy them out but if not everyone agrees to sell). More so to make sure everyones thoughts are aligned and it doesn't become an argument later. 

silvercar said:

penners324 said:

So the kids will have to pay additional SDLT every time they want to buy a new house.

They will have to pay CGT if and it's sold.

It'll become part of their estate, so they would have split their share, in cash, if they get divorced.

It'll likely be seen as deprivation of assets if you go into a care home.

I thought deprivation of assets only kicked in if you showed any signs of needing care at the time of the gift?
In any case, we have sufficient for our care earmarked elsewhere.

Extra SDLT on moving PPR won't apply as they already have a PPR each that they can replace if they decide to move.

We'd be lumbered with CGT on sale, as would they; so that won't make a difference. Same as we'd be saddled with extra SDLT on purchase as would they.

No, the point is it'll presumably be sold one day (likely after your death). If in the kids names they'd pay CGT on the increase from today -> sale, while if in your name then there's 0 CGT from today -> your death date, albeit replaced by IHT. 
You're treating it as saving the whole IHT, but actually you're only saving part, the rest offsets the CGT saving. If you live a long time and hence there's a large gain racked up, the saving could become small. 

There's already one DiL (and grandchild) in the picture, we can hardly make demands at this point. There is no bartering power - "if you divorce I want you to agree X" is an odd conversation to have when she's already part of the family. 

Isthisforreal99

silvercar said:

saajan_12 said:

silvercar said:

Grumpy_chap said:

silvercar said:

Just musing at this point.

We have a holiday home abroad that we are considering selling. I know CGT will be payable, here and abroad. If we do sell, we would then buy a holiday home in the UK to make travelling easier than having to fly abroad. 

We are early 60s with 2 adult children in their 30s who are already home owners.

To avoid future IHT (we live near London, so thanks to HPI and having bought young, our estate on 2nd death will be liable for IHT) I am thinking it would be sensible to buy the property in the name of our 2 children, so out of the IHT loop if we survive 7 years.

The property would be kept for the sole use of family, not rented out. Whether the ownership is in our name or our children's name, the property would be available for use by immediate family/ siblings/ niblings only with no rent changing hands.

Any disadvantages tax wise, in putting it in the names of adult children?

So, you will sell your holiday home overseas and pay all the taxes that arise.

This will provide you with a lump sum of cash and you wish to be able to pass that lump sum to your two children such that they benefit from the asset value and the potential IHT can be avoided assuming you survive 7 years.

Why not simply pass the children half of the cash value each, with no strings attached?  That way, the two children can make their own decisions as to what they wish to do with the cash value received to suit their own current and future priorities.

What appears to be proposed is to "gift" half the cash value to each of the children but with the reservation that the value has to be used to pay for half of a holiday home which will be made available to you and other family members for use for holidays without charge of any kind.
This is really sounding like a Gift with Reservation (GWR) so would fail to take the value out of your Estate for IHT purposes.

As you and both children are all home owners, second property stamp duty premium will apply on acquisition.

Second-property Council Tax will apply.

CGT will apply on disposal.  The only way to avoid CGT would be if the property is still owned by the (by then) deceased at time of death.

Who has priority in deciding who can take their holiday in the holiday cottage when?  What if the two children and their families and you all want the same October half term week?

What happens if the children divorce / split from their partners and the now-ex wants to claim the quarter value of the holiday cottage as part of the separation?  Would that require a forced sale?

What happens if the children ever need to claim means-tested benefits?  The share of equity in the holiday cottage would be considered as capital and most likely exclude eligibility for means-tested benefits.

Partner issues are a valid point, but if you worried too much about that, you would not help your adult children in the way you would like. At the end of the day, in accepting a gift from parents, the kids have to accept that if their relationship collapsed they would have the consequences, but we can't not give them anything in case they break up and their ex's end up with some of our money. Otherwise they wouldn't have got on the property ladder in the first place.

 

I agree with this in principle, that it shouldn't be a blocker to what you want to do with yoru money, but I think its very much worth worring / planning for. Eg get an agreement in place on what happens in divorce (you can't just say the partner gets nothing, but maybe the others could optionally buy them out but if not everyone agrees to sell). More so to make sure everyones thoughts are aligned and it doesn't become an argument later. 

silvercar said:

penners324 said:

So the kids will have to pay additional SDLT every time they want to buy a new house.

They will have to pay CGT if and it's sold.

It'll become part of their estate, so they would have split their share, in cash, if they get divorced.

It'll likely be seen as deprivation of assets if you go into a care home.

I thought deprivation of assets only kicked in if you showed any signs of needing care at the time of the gift?
In any case, we have sufficient for our care earmarked elsewhere.

Extra SDLT on moving PPR won't apply as they already have a PPR each that they can replace if they decide to move.

We'd be lumbered with CGT on sale, as would they; so that won't make a difference. Same as we'd be saddled with extra SDLT on purchase as would they.

No, the point is it'll presumably be sold one day (likely after your death). If in the kids names they'd pay CGT on the increase from today -> sale, while if in your name then there's 0 CGT from today -> your death date, albeit replaced by IHT. 
You're treating it as saving the whole IHT, but actually you're only saving part, the rest offsets the CGT saving. If you live a long time and hence there's a large gain racked up, the saving could become small. 

There's already one DiL (and grandchild) in the picture, we can hardly make demands at this point. There is no bartering power - "if you divorce I want you to agree X" is an odd conversation to have when she's already part of the family. 

Have you actually had any conversation with the kids on your musings? What if they want no part of it?

silvercar

Isthisforreal99 said:

silvercar said:

saajan_12 said:

silvercar said:

Grumpy_chap said:

silvercar said:

Just musing at this point.

We have a holiday home abroad that we are considering selling. I know CGT will be payable, here and abroad. If we do sell, we would then buy a holiday home in the UK to make travelling easier than having to fly abroad. 

We are early 60s with 2 adult children in their 30s who are already home owners.

To avoid future IHT (we live near London, so thanks to HPI and having bought young, our estate on 2nd death will be liable for IHT) I am thinking it would be sensible to buy the property in the name of our 2 children, so out of the IHT loop if we survive 7 years.

The property would be kept for the sole use of family, not rented out. Whether the ownership is in our name or our children's name, the property would be available for use by immediate family/ siblings/ niblings only with no rent changing hands.

Any disadvantages tax wise, in putting it in the names of adult children?

So, you will sell your holiday home overseas and pay all the taxes that arise.

This will provide you with a lump sum of cash and you wish to be able to pass that lump sum to your two children such that they benefit from the asset value and the potential IHT can be avoided assuming you survive 7 years.

Why not simply pass the children half of the cash value each, with no strings attached?  That way, the two children can make their own decisions as to what they wish to do with the cash value received to suit their own current and future priorities.

What appears to be proposed is to "gift" half the cash value to each of the children but with the reservation that the value has to be used to pay for half of a holiday home which will be made available to you and other family members for use for holidays without charge of any kind.
This is really sounding like a Gift with Reservation (GWR) so would fail to take the value out of your Estate for IHT purposes.

As you and both children are all home owners, second property stamp duty premium will apply on acquisition.

Second-property Council Tax will apply.

CGT will apply on disposal.  The only way to avoid CGT would be if the property is still owned by the (by then) deceased at time of death.

Who has priority in deciding who can take their holiday in the holiday cottage when?  What if the two children and their families and you all want the same October half term week?

What happens if the children divorce / split from their partners and the now-ex wants to claim the quarter value of the holiday cottage as part of the separation?  Would that require a forced sale?

What happens if the children ever need to claim means-tested benefits?  The share of equity in the holiday cottage would be considered as capital and most likely exclude eligibility for means-tested benefits.

Partner issues are a valid point, but if you worried too much about that, you would not help your adult children in the way you would like. At the end of the day, in accepting a gift from parents, the kids have to accept that if their relationship collapsed they would have the consequences, but we can't not give them anything in case they break up and their ex's end up with some of our money. Otherwise they wouldn't have got on the property ladder in the first place.

 

I agree with this in principle, that it shouldn't be a blocker to what you want to do with yoru money, but I think its very much worth worring / planning for. Eg get an agreement in place on what happens in divorce (you can't just say the partner gets nothing, but maybe the others could optionally buy them out but if not everyone agrees to sell). More so to make sure everyones thoughts are aligned and it doesn't become an argument later. 

silvercar said:

penners324 said:

So the kids will have to pay additional SDLT every time they want to buy a new house.

They will have to pay CGT if and it's sold.

It'll become part of their estate, so they would have split their share, in cash, if they get divorced.

It'll likely be seen as deprivation of assets if you go into a care home.

I thought deprivation of assets only kicked in if you showed any signs of needing care at the time of the gift?
In any case, we have sufficient for our care earmarked elsewhere.

Extra SDLT on moving PPR won't apply as they already have a PPR each that they can replace if they decide to move.

We'd be lumbered with CGT on sale, as would they; so that won't make a difference. Same as we'd be saddled with extra SDLT on purchase as would they.

No, the point is it'll presumably be sold one day (likely after your death). If in the kids names they'd pay CGT on the increase from today -> sale, while if in your name then there's 0 CGT from today -> your death date, albeit replaced by IHT. 
You're treating it as saving the whole IHT, but actually you're only saving part, the rest offsets the CGT saving. If you live a long time and hence there's a large gain racked up, the saving could become small. 

There's already one DiL (and grandchild) in the picture, we can hardly make demands at this point. There is no bartering power - "if you divorce I want you to agree X" is an odd conversation to have when she's already part of the family. 

Have you actually had any conversation with the kids on your musings? What if they want no part of it?

As I said in the title, I'm at the musing stage, so no family discussion yet. Though I can't see any objection to having something in their name, if we are paying all expenses going forward and doing all the paperwork, in return for which they should avoid some IHT.  

Grumpy_chap

silvercar said:

As I said in the title, I'm at the musing stage, so no family discussion yet. Though I can't see any objection to having something in their name, if we are paying all expenses going forward and doing all the paperwork, in return for which they should avoid some IHT.  

Except that looks so clearly like GWR (gift with reservation) that the value will still be in your Estate for IHT purposes.

You will, though, guarantee that the children incur a CGT liability which might otherwise be avoided if you still own the holiday cottage in your name at the time of your death.

The children will likely become ineligible for means tested benefits should they fall on hard times.

Isthisforreal99

silvercar said:

Isthisforreal99 said:

silvercar said:

saajan_12 said:

silvercar said:

Grumpy_chap said:

silvercar said:

Just musing at this point.

We have a holiday home abroad that we are considering selling. I know CGT will be payable, here and abroad. If we do sell, we would then buy a holiday home in the UK to make travelling easier than having to fly abroad. 

We are early 60s with 2 adult children in their 30s who are already home owners.

To avoid future IHT (we live near London, so thanks to HPI and having bought young, our estate on 2nd death will be liable for IHT) I am thinking it would be sensible to buy the property in the name of our 2 children, so out of the IHT loop if we survive 7 years.

The property would be kept for the sole use of family, not rented out. Whether the ownership is in our name or our children's name, the property would be available for use by immediate family/ siblings/ niblings only with no rent changing hands.

Any disadvantages tax wise, in putting it in the names of adult children?

So, you will sell your holiday home overseas and pay all the taxes that arise.

This will provide you with a lump sum of cash and you wish to be able to pass that lump sum to your two children such that they benefit from the asset value and the potential IHT can be avoided assuming you survive 7 years.

Why not simply pass the children half of the cash value each, with no strings attached?  That way, the two children can make their own decisions as to what they wish to do with the cash value received to suit their own current and future priorities.

What appears to be proposed is to "gift" half the cash value to each of the children but with the reservation that the value has to be used to pay for half of a holiday home which will be made available to you and other family members for use for holidays without charge of any kind.
This is really sounding like a Gift with Reservation (GWR) so would fail to take the value out of your Estate for IHT purposes.

As you and both children are all home owners, second property stamp duty premium will apply on acquisition.

Second-property Council Tax will apply.

CGT will apply on disposal.  The only way to avoid CGT would be if the property is still owned by the (by then) deceased at time of death.

Who has priority in deciding who can take their holiday in the holiday cottage when?  What if the two children and their families and you all want the same October half term week?

What happens if the children divorce / split from their partners and the now-ex wants to claim the quarter value of the holiday cottage as part of the separation?  Would that require a forced sale?

What happens if the children ever need to claim means-tested benefits?  The share of equity in the holiday cottage would be considered as capital and most likely exclude eligibility for means-tested benefits.

Partner issues are a valid point, but if you worried too much about that, you would not help your adult children in the way you would like. At the end of the day, in accepting a gift from parents, the kids have to accept that if their relationship collapsed they would have the consequences, but we can't not give them anything in case they break up and their ex's end up with some of our money. Otherwise they wouldn't have got on the property ladder in the first place.

 

I agree with this in principle, that it shouldn't be a blocker to what you want to do with yoru money, but I think its very much worth worring / planning for. Eg get an agreement in place on what happens in divorce (you can't just say the partner gets nothing, but maybe the others could optionally buy them out but if not everyone agrees to sell). More so to make sure everyones thoughts are aligned and it doesn't become an argument later. 

silvercar said:

penners324 said:

So the kids will have to pay additional SDLT every time they want to buy a new house.

They will have to pay CGT if and it's sold.

It'll become part of their estate, so they would have split their share, in cash, if they get divorced.

It'll likely be seen as deprivation of assets if you go into a care home.

I thought deprivation of assets only kicked in if you showed any signs of needing care at the time of the gift?
In any case, we have sufficient for our care earmarked elsewhere.

Extra SDLT on moving PPR won't apply as they already have a PPR each that they can replace if they decide to move.

We'd be lumbered with CGT on sale, as would they; so that won't make a difference. Same as we'd be saddled with extra SDLT on purchase as would they.

No, the point is it'll presumably be sold one day (likely after your death). If in the kids names they'd pay CGT on the increase from today -> sale, while if in your name then there's 0 CGT from today -> your death date, albeit replaced by IHT. 
You're treating it as saving the whole IHT, but actually you're only saving part, the rest offsets the CGT saving. If you live a long time and hence there's a large gain racked up, the saving could become small. 

There's already one DiL (and grandchild) in the picture, we can hardly make demands at this point. There is no bartering power - "if you divorce I want you to agree X" is an odd conversation to have when she's already part of the family. 

Have you actually had any conversation with the kids on your musings? What if they want no part of it?

As I said in the title, I'm at the musing stage, so no family discussion yet. Though I can't see any objection to having something in their name, if we are paying all expenses going forward and doing all the paperwork, in return for which they should avoid some IHT.  

It's not just 'in name' though is it. You are making this sound like some selfless act of genorisity when all it seems is some contrived attempt at tax avoidance further down the line and I would say leave the children out of it unless they are prepared to accept the potentially wide ranging implications for them in years to come.

silvercar

Grumpy_chap said:

silvercar said:

As I said in the title, I'm at the musing stage, so no family discussion yet. Though I can't see any objection to having something in their name, if we are paying all expenses going forward and doing all the paperwork, in return for which they should avoid some IHT.  

Except that looks so clearly like GWR (gift with reservation) that the value will still be in your Estate for IHT purposes.

You will, though, guarantee that the children incur a CGT liability which might otherwise be avoided if you still own the holiday cottage in your name at the time of your death.

The children will likely become ineligible for means tested benefits should they fall on hard times.

Maybe we should all own it between us, so there would be no accusations of a GWR. I'm confused with this being a GWR, if they own it and have first dibs on when they can use it, so we only use it when empty, why is it a GWR. 

mybestattempt

silvercar said:

Grumpy_chap said:

silvercar said:

As I said in the title, I'm at the musing stage, so no family discussion yet. Though I can't see any objection to having something in their name, if we are paying all expenses going forward and doing all the paperwork, in return for which they should avoid some IHT.  

Except that looks so clearly like GWR (gift with reservation) that the value will still be in your Estate for IHT purposes.

You will, though, guarantee that the children incur a CGT liability which might otherwise be avoided if you still own the holiday cottage in your name at the time of your death.

The children will likely become ineligible for means tested benefits should they fall on hard times.

Maybe we should all own it between us, so there would be no accusations of a GWR. I'm confused with this being a GWR, if they own it and have first dibs on when they can use it, so we only use it when empty, why is it a GWR. 

Splitting legal ownership between yourselves and children would not prevent the share owned by each child from being a GWR.

To claim the holiday home (or any share of it) is not a GWR then you and your husband (the donors) must be entirely or virtually excluded from it.

This HMRC guidance explains:

https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14333

As you will see HMRC will consider even occasionally using a holiday home as significant.

As part of your musing you should perhaps consider the possibility of leaving your executors a dispute with HMRC about the holiday home.