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John Gossage. It isn't as simple as you make out and as anon at 2.18 has rightly pointed out HMRC's manual isn't always accurate and indeed HMRC has been know to put forward arguments contrary to its own manual
You refer in ascertaining whether one might be liable to higher rate sdlt to include a property in which you have an interest as a beneficiary of a trust but that is not entirely correct as again anon at 2.18 alludes to and to do so could result in one needlessly paying higher rate sdlt

I cannot see the supine CLC going anywhere near the matter. It is to the SRA what Mr Barroclough out of Porridge is to Judge Pickles ( regrettably showing my age)