IHTM27263 - Foreign property: specific British 바카라 사이트 Securities: exempt securities in unadministered estates
IHTA84/S91 says that for Inheritance Tax, a person with an interest in possession (absolute or limited) in all or part of a deceased person바카라 사이트™s residuary estate is treated as having a corresponding direct interest in the net assets for the time being held in the residuary estate. So, any exempt securities included in an unadministered estate can qualify as excluded property if they are transferred by someone entitled to an interest in possession in that estate, depending on:Ìý
what conditions those securities were issued under바카라 사이트¯IHTM27241바카라 사이트¯a²Ô»åÌý
that person satisfying those conditions.Ìý
ExampleÌý
Sharon dies leaving her residuary estate to Boris and Clive equally. Before the estate has been administered, Clive - who is residentÌýabroad - assigns his interest in the estate to the trustees of a discretionary trust. At the time of the assignment the estate includes holdings of exempt securities and some other UK assets.Ìý
Clive바카라 사이트™s assignment is a transfer of value, which is not a PET. For the purpose ofÌýdeterminingÌýthe value transferred, Clive바카라 사이트™s interest in exempt securities included in Sharon바카라 사이트™s estate is excluded property, so the securities are left out of Clive바카라 사이트™s estate. The value is worked out by reference to the remaining assets.