IHTM22081 - Quantifying increase at deceased's estate: special provisions for reversions
In most cases a reversionary interest (IHTM16231) is treated as excluded property (IHTM04251) for Inheritance Tax. When you calculate the increase in your deceased바카라 사이트™s estate on the earlier chargeable transfer (IHTM04027), you should ignore any such reversionary interest which your deceased became entitled to before, or on, the earlier chargeable transfer.
Example
Virat by his Will leaves assets to Ishant for life. After Ishant dies the assets pass to Ravi absolutely. During Ishant바카라 사이트™s lifetime Ravi has a reversionary interest in the assets.
The reversion which Ravi acquires under Virat바카라 사이트™s Will in fact increases his estate. But because of IHTA84/S141(6) the reversion does not increase Ravi바카라 사이트™s estate for the purposes of quick succession relief (QSR) (IHTM22041).
So
- there can be no QSR on Ravi바카라 사이트™s death for the tax charged on Virat바카라 사이트™s death
- if Ravi dies after Ishant, you calculate the QSR for tax payable on Ishant바카라 사이트™s death on the basis that the increase in Ravi바카라 사이트™s estate on Ishant바카라 사이트™s death was the value of the settled fund at Ishant바카라 사이트™s death, less the tax payable on it.
(The increase is not limited to the difference between the value and the value of Ravi바카라 사이트™s pre-existing reversion.)
IHTA84/S141(6) is necessary to achieve this result because the excluded property provisions in IHTA84/S3(2), IHTA84/S5(1) and IHTA84/S48(1) do not apply for the purposes of IHTA84/S141.