Commentary

I5.533 Depreciatory transactions within an A&M trust

IHT, trusts and estates

I5.533 Depreciatory transactions within an A&M trust

I5.533 Depreciatory transactions within an A&M trust

Where the accumulation and maintenance (A&M) trust regime does not cease to apply to settled property, but the trustees make a disposition as a result of which the value of the settled property is less than it would be but for the disposition, there is a charge to IHT on the diminution in value of the property1. The amount on which tax is charged is provided in IHTA 1984, s 70(5) — see I5.643.

A disposition includes an omission to exercise a right (unless shown not to be deliberate)2. Where the trustees are participators

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