Commentary

I1.518 Partial exemption

IHT, trusts and estates

I1.518 Partial exemption

I1.518 Partial exemption

Apart from the special cases of death for the estates of police constables and service personnel (I4.209)1, emergency service personnel and humanitarian aid workers (I4.210)2 and members of the armed forces (I4.211)3, exemption is usually available according to the characteristics of the recipient of a gift—eg gifts to the deceased's spouse or civil partner, or to charity are exempt while gifts to the deceased's children or friends are not. It is very common for the dispositions taking effect on death to be a mixture of exempt and non-exempt gifts, while the deemed transfer of value on death is of the deceased's estate treated as a single bundle of assets. A complex set of rules (see I4.231–I4.243)

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