Commentary

I8.332 Forming a new partnership

IHT, trusts and estates

I8.332 Forming a new partnership

I8.332 Forming a new partnership

When a new partnership is formed, if the benefits and commitments of the partners are not broadly equal (they can be equal without being identical) there might be an immediate transfer of value1 by one or more of the partners.

Clearly an immediate transfer of value arises if a father provides the whole of the partnership capital and credits his son with half of it without receiving any consideration. On the other hand, where no capital changes hands and each partner is entitled to payment for his share in full on death or retirement, no transfer

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