Commentary

I7.150A BPR and successions

IHT, trusts and estates

I7.150A BPR and successions

I7.150A BPR and successions

Where the transferor became entitled to an interest in a business or a holding securities or shares on a death and has not 'owned' the asset long enough to satisfy the two-year rule, his ownership is deemed to have begun on the date of the death, and if the death was that of a spouse or civil partner he is deemed to have owned it for any period during which the spouse or civil partner owned it1, irrespective of how long they had been married or in a civil partnership2.

It is doubtful whether strictly this applies

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