Commentary

I5.549A Tax implications of TBMs—depreciatory transfers

IHT, trusts and estates

I5.549A Tax implications of TBMs—depreciatory transfers

I5.549A Tax implications of TBMs—depreciatory transfers

Where the trustees of a trust for bereaved minors (TBM) make a disposition as a result of which the value of 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. For the amount on which tax is charged see I5.643.

A disposition includes an omission to exercise a right (unless shown not to be deliberate)2, and (where the trustees are participators in a close company) an alteration in the company's share capital (or rights attached to it3—see I6.101)

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