Commentary

I4.239A Attribution procedure where there is partly exempt residue

IHT, trusts and estates

I4.239A Attribution procedure where there is partly exempt residue

I4.239A Attribution procedure where there is partly exempt residue

Where there are both specific gifts and division of residue between exempt and non-exempt beneficiaries, it is necessary:

  1.  

    •     to calculate 'the assumed amount of tax'

  2.  

    •     to calculate 'the assumed rate of tax'

  3.  

    •     to gross up those specific gifts or those parts of specific gifts where grossing up is necessary at the assumed rate of tax

  4.  

    •     to calculate the total value attributable to specific gifts

  5.  

    •     to calculate the total value attributable to residuary gifts

  6.  

    •     to calculate the actual rate of tax, and

  7.  

    •     to apply that

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