Commentary

I6.128 Cumulation and close companies

IHT, trusts and estates

I6.128 Cumulation and close companies

I6.128 Cumulation and close companies

Where part of the value transferred by a close company's transfer of value is treated as a chargeable transfer made by a participator, the gross amount chargeable is cumulated with his other transfers in the usual way1. Where, however, not more than 5% of the value transferred by the company is apportioned to a particular participator, IHTA 1984, s 94(4) provides that the 'tax chargeable under [IHTA 1984, s 94(1)] above shall be left out of account in determining with respect to any time after the company's transfer, what previous transfers of value he has

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