Commentary

I12.506 Freezing operations

IHT, trusts and estates

I12.506 Freezing operations

I12.506 Freezing operations

This idea involves the reorganisation of share capital whereby the capital of a company is divided into two classes of shares. The owner/proprietor retains one class of shares, which carries the entitlement to the current value of the company. Thereafter, a new class of shares is created with very little current value but designed to absorb the future growth. This class of shares is allocated to the intended donee (eg the proprietor's children, or the trustees of appropriate trusts for his or her grandchildren). Care will have to be taken that IHTA 1984, s 98 does

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