Commentary

I5.1150 Application of remittance basis to the charge on onward gifts

IHT, trusts and estates

I5.1150 Application of remittance basis to the charge on onward gifts

I5.1150 Application of remittance basis to the charge on onward gifts

Where income is treated as arising to an individual for a tax year under ITTOIA 2005, s 643J at I5.1147 or ITTOIA 2005, s 643L at I5.1148, and the individual is chargeable on the remittance basis for that year, the income is treated as relevant foreign income of the individual, with the consequences in E1.603 (ignoring split year treatment where an individual is UK resident for part only of a tax year).

For the purposes of applying the remittance basis, the onward payment, or (as the case may

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