Commentary

I4.238 Attribution where there are tax-free and subject to tax gifts (double grossing)

IHT, trusts and estates

I4.238 Attribution where there are tax-free and subject to tax gifts (double grossing)

I4.238 Attribution where there are tax-free and subject to tax gifts (double grossing)

Specific gifts not bearing their own tax may not be the only gifts with respect to which the transfer is chargeable, for example, there may be other chargeable specific gifts which do bear their own tax, or residue or a share of it may be chargeable.

The rate at which specific gifts not bearing their own tax should be grossed up must take account of the existence of these other chargeable gifts. This is achieved by a double grossing up formula.

There are four stages as follows1:

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