Commentary

I4.144 Offshore funds and deep discount securities

IHT, trusts and estates

I4.144 Offshore funds and deep discount securities

I4.144 Offshore funds and deep discount securities

Offshore funds

A deduction is given against a person's estate immediately before death in two circumstances where death itself gives rise to an income tax liability. The offshore fund regulations charge to tax gains arising on the disposal of an interest in a non-reporting fund (see B5.705)1. Broadly speaking the object of the legislation is to prevent the accumulation of income in such a fund for the benefit of UK residents and, in effect, charge only to capital gains tax when the UK resident sells his interest, for example, to the fund managers,

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