IHTM04274 - Foreign settled property: identifying settled property
The expression 바카라 사이트˜property comprised in a settlement바카라 사이트™ in IHTA84/S48 (3) means the items of property (IHTM04030) held in the settlement (IHTM16042) at the time of the chargeable event you are considering. In determiningÌýthe locality (IHTM27071) of any particular property you should consider the property in its current form and not its previousÌý³ó¾±²õ³Ù´Ç°ù²â.Ìý
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ExampleÌý
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ÌýStella, whoÌýis never aÌýlong-term UK residentÌý(IHTM47000), transfers a house in Germany바카라 사이트¯and some UK securities바카라 사이트¯into a settlement for XavierÌý(also not a long-term UK resident)Ìýfor his life with remainderÌýto Yolanda. On Xavier바카라 사이트™s death - the potentially chargeable event - the settled fund consists of:
Option 1: a villa in Spain.Ìý
Option 2: land in the UK.Ìý
Option 3: a house in Spain and some바카라 사이트¯UK securities.Ìý
With Option 1 the villa is excluded property even though it partly representsÌýthe proceeds of what was previously UK property (the securities).Ìý
The land in바카라 사이트¯Option 2바카라 사이트¯is not excluded property although it is partly derived from the proceeds of sale of the German house.Ìý
In Option 3 the house in Spain바카라 사이트¯is excluded property but the UK securities are not.