Commentary

I3.213 Options as transfers of value

IHT, trusts and estates

I3.213 Options as transfers of value

I3.213 Options as transfers of value

Where a person has a right or option to purchase property at a beneficial price, the difference between the beneficial option price and the full open market value forms part of his estate during his lifetime1.

If the individual dies without exercising the option, and the benefit passes to their personal representatives, it forms part of their estate on his death. If the option is personal to them, and expires on a certain date, the omission to exercise it on that date would give rise to a charge unless it can be shown that

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