Commentary

68 Powers of appointment in relation to inheritance tax

POWERS OF APPOINTMENT vol 33
| Commentary

68 Powers of appointment in relation to inheritance tax

| Commentary

68 Powers of appointment in relation to inheritance tax

Inheritance tax is charged on transfers of value1. A transfer of value occurs where there is a disposition by a person (the transferor) which results in his estate falling in value2. In general, inheritance tax becomes payable by reason of a devolution of property on death. However, lifetime dispositions may also be taxed, for example where the transferor dies within seven years of making certain dispositions3, or where the disposition results in property being transferred into a relevant property trust4.

Where a person omits to exercise a right and that omission results

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