IHTM34220 - Restrictions on relief: part holdings comprised in the deceased바카라 사이트™s estate
This restriction applies if only part of the holding is included in the deceased바카라 사이트™s estate. The loss on sale, restricted as necessary, is deducted from the value of the entirety of the investments. The resulting figure is then apportioned according to the values of:
- the part of the holding comprised in the estate, and
- the entirety of that holding, IHTA84/S186.
Example
Aries trust fund comprises 1,000 Black plc shares, valued immediately before death at £4,000. Of this 250 shares with a value of £1,000 is comprised in the deceased바카라 사이트™s estate.
Two months after the death the holding is sold for £3,000. The overall loss on sale is £1,000 and the value of the entirety of the holding after relief becomes £3,000.
The value of that part of the holding comprised in the estate is revised to
(1,000 ÷ 4,000) x £3,000 = £750