Commentary

I4.149G Liabilities which are used to finance foreign currency bank accounts

IHT, trusts and estates

I4.149G Liabilities which are used to finance foreign currency bank accounts

I4.149G Liabilities which are used to finance foreign currency bank accounts

As set out above (at I4.124), the transfer of value deemed to be made immediately before death does not include a foreign currency bank account of the deceased if the deceased is neither domiciled nor resident in the UK1. The balance of a foreign currency bank account which falls within IHTA 1984, s 157 is left out of account when calculating the value of the estate. In the case of transfers of value taking place or deemed to take place after 17 July 20142, where the deceased has incurred a liability to fund a foreign currency account, which is left out of account under IHTA 1984, s 157, that liability is not deductible from the value of the deceased's estate save insofar as the liability exceeds the value of the foreign currency account3.

The provisions which disallow the deduction of the liability operate in a similar way to the provisions which disallow the deduction of a liability used to finance or enhance

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