My client is the legal owner of a furnished holiday let (FHL) which several years ago was the subject of a deed placing the beneficial ownership into the names of my client and his wife equally.

As FHLs are excluded from the deemed 50/50 income rule for spouses, the income was disclosed in a more tax efficient manner. In view of the abolition of FHLs, does this mean that the exclusion from the 50/50 rule will no longer apply and that the income will be based on the equal ownership?