Commentary

I8.243C Selling instead of giving

IHT, trusts and estates

I8.243C Selling instead of giving

I8.243C Selling instead of giving

The particular problem facing parents owning a holding in excess of 50% of the voting shares in a large private company, either between them or individually, is that their children will probably not be able to purchase the shares en bloc and, if the parents give them or sell them piecemeal to their children, they face a sudden disproportionate tax charge on the transfer which reduces the related holding to or below 50%.

Example

Y Ltd is a private family investment company with an issued capital of £100,000 represented by 100,000 £1 ordinary shares.

Shareholdings of various sizes are valued as follows:

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial