Commentary

I5.282 Termination on death of life tenant

IHT, trusts and estates

I5.282 Termination on death of life tenant

I5.282 Termination on death of life tenant

Where someone dies whilst entitled to a qualifying interest in possession (QIIP), the property which was subject to the QIIP is charged to tax as part of the deemed transfer of value on death as described in I5.241. The calculation of the tax is as described in I4.161–I4.164 for the estate on death.

The overall amount of tax is then apportioned between the non-exempt free estate and the non-exempt settled property rateably according to value, save where the settled property is subject to the 'special rate' (see I3.527), and

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