Commentary

I9.321A Securities in absolute ownership

IHT, trusts and estates

I9.321A Securities in absolute ownership

I9.321A Securities in absolute ownership

Exempt government securities (see I9.321) are excluded property if they are in the beneficial ownership of a person who satisfies the conditions for exemption attached to the stock1. These conditions are, for most exempt stock, that the beneficial owner is resident (prior to 6 April 2013, ordinarily resident) outside the UK2; see I9.321.

The exemption depends on the qualifying person having beneficial ownership and not the mere legal title. HMRC state that at the date of the transfer concerned the securities must in fact be registered in the name of the transferor3. Where large sums

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