Commentary

I4.237 Attribution where only tax-free gifts are chargeable (single grossing)

IHT, trusts and estates

I4.237 Attribution where only tax-free gifts are chargeable (single grossing)

I4.237 Attribution where only tax-free gifts are chargeable (single grossing)

The simple formula described in I4.236 does not work where a testator makes one or more specific gifts which are chargeable (whether in whole or in part) and which do not bear their own tax, ie, tax is payable out of residue.

In these circumstances the size of the chargeable part of the transfer will need to reflect the payment of tax on the specific gifts out of another part of the value transferred.

To repeat, death is an event on which IHT is charged as if a transfer of value

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