Your younger son is asking you to leave half your estate not to him but to his children because receiving the money would cause tax problems for him - I can’t see what these might be until he dies and his estate attracts IHT, unless interest on the inheritance might put him into the additional tax band, though if he’s so successful I would expect him to be paying tax at the additional, rather than higher, rate already. I expect he has ‘done his sums’. If that’s what he wants then honour his request, maybe leave him some personal item of his choice and leave the remainder to your other son. You can place a letter with your will to explain why you have divided your estate in the way you have. I would always suggest getting a solicitor to prepare a will as you need to consider the possibility of either son predeceasing you or having more children.