IHTM16245 - Close companies and settled property: alterations in capital or rights
IHTA84/S100 provides the method of dealing with alterations in a close company바카라 사이트™s (IHTM14851) capital or rights where the participator is a trustee and an interest in possession, in whole or part, subsists in the fund.
This special provision is needed because in the case of 바카라 사이트˜alterations of capital or rights바카라 사이트™ there is no transfer of value as required by IHTA84/S99.
IHTA84/S100 (1) identifies the person with the life interest and S100 (2) spells out what value to tax. This is 바카라 사이트˜such part of the individual바카라 사이트™s interest shall be treated as coming to an end at the time of the alteration as corresponds to the relevant decrease of the value of the property in which the interest subsists, that is to say the decrease caused by the alteration.바카라 사이트™ Essentially it means calculating the value 바카라 사이트˜before바카라 사이트™ and the value 바카라 사이트˜after바카라 사이트™ and taxing the difference.
Such a claim, occurring after 16 March 1987, will be a PET (IHTM04057) if it would have been so under a typical IHTA84/S52 (1) claim.