Commentary

I12.505 Company reconstructions

IHT, trusts and estates

I12.505 Company reconstructions

I12.505 Company reconstructions

In the CTT era, when rates were in excess of 60%, a number of ideas emerged which involved reorganisation of share capital. Generally speaking, a combination of the reduction of the highest rate of IHT to 40% in 1988 coupled with the dramatic increase in the rates of business property relief has caused these ideas to fall out of fashion. However, they may continue to be relevant where business property relief is not available (as where a client holds shares in an investment company) and a brief summary of the relevant ideas is therefore included.

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