Commentary

I4.111 Estate on death generally

IHT, trusts and estates

I4.111 Estate on death generally

The death estate

I4.111 Estate on death generally

As mentioned in I4.101, the IHT charge on death extends to the value of a person's estate immediately before his death1. For the purposes of the IHT legislation a person's estate is in general the aggregate of all the property to which he is beneficially entitled2, less his liabilities3. If he has a qualifying interests in possession (QIIP — see I5.201) in settled property, that property is deemed to be property to which he is beneficially entitled and thus forms part of his taxable estate4 (unless the reverter to settlor or estate duty surviving spouse exemption apply — see I4.131, I5.921). 'Property' includes rights and interests of any description5.

The fact that it is the aggregate of property to which he is beneficially entitled means that, for

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