Capital Taxes Update and Planning 2017 Martyn Ingles FCA CTA
CGT Update - Agenda PPR refresher Relief for gifts business assets and using trusts Goodwill on incorporation worth doing again? Transfer of rental business to Ltd company Entrepreneurs relief watch 5% rule Liquidations CGT or income tax? Making Seed EIS work for your clients IHT planning including the new downsizing relief
Private Residences Taxpayer s main residence exempt Includes grounds of 0.5ha Or required for reasonable enjoyment having regard to size and character Includes servants quarters And buildings in curtilage
Private Residence Planning If 2 or more residences May elect which is principal residence Only one at time Switch back and forth Last 18 months owned then exempt (was 36m) Acceptable tax avoidance per GAAR guidance
Not a Residence for CGT PPR Moore v HMRC FTT decision Property initially a Buy to Let Marriage break up moved in to property 12.11.06 Council tax records support this Property sold 22.7.2007 = 8 months later Put property on market with Estate Agent 22.4.2007 Date moved in with new girlfriend? unclear Post delivered to girlfriend s address (2 nd wife)
Not a Residence for CGT PPR HMRC s view - Mr Moore s occupation did not have the degree of permanence, continuity or expectation of continuity necessary for the property to qualify as his only or main residence for the purposes of sections 222 and 223 TCGA. Goodwin v Curtis A person s home was to be distinguished from a property which the person temporarily occupied FTT rejected taxpayers appeal NOT PPR
Child at University? Extra PPR Trustees get PPR if beneficiary lives in house Martyn s daughter Hannah buy flat in Manchester? 3 options: 1. Martyn buys not PPR 2. Hannah buys, Martyn as guarantor (her PPR) 3. Buy via trust PPR available to trustees (With 3, Martyn should not lend funds to trust could invoke the settlements rule he should guarantee the Trust borrowing or settle funds absolutely)
CGT payable by nonresidents from 2015/16
CGT payable by non-residents Consultation in Summer 2014 New charge from 6 April 2015 on disposal of UK residential properties (dwellings) Applies to NR individuals, trustees and close companies Rebase at 6 April 2015 Can they claim PPR relief? Report and Pay CGT within 30 days - HMRC online calculator
CGT payable by non-residents Example 2 Frau Merkel lives in Germany bought a holiday cottage in England April 2005 for 500,000, uses 2 weeks/ year. Sells the cottage in April 2020 for 650,000. Market value of the cottage on 6 April 2015 was 550,000. Gain computed with ref to 6 April 2015 value 100,000. Time apportioned gain on cost 150,000 x 5/15 = 50,000 Elect to use the time apportionment basis
Private Residence Relief for Non-Residents PPR will still be available to non-residents disposing of main residence in Uk Consultation considered 2 options: 1. Remove election - HMRC may seek evidence that defacto main residence mail delivery, electoral roll. 2. A fixed rule to identify the main residence based on number of days spent there New legislation requires occupation for at least 90 days in the tax year concerned to qualify for PPR
Relief for gifts Business assets and trust planning
Hold over (gift) relief Two alternatives S165 gift of business assets Are the shares a business asset? S260 transfers subject to immediate IHT charge Lifetime transfers to most trusts now Can be any asset
S165 business gift relief Shares in trading company Up to 5.4.03 linked to retirement relief definition Trading company = wholly or mainly test CBA/CA restriction if personal company Now linked to trading company 20% test
CBA/ CA restriction Where shareholder has >25% or personal company Restrict gain available for holdover To MV chargeable business assets portion Goodwill? Old or new?
CBA/ CA restriction Example Business premises 300,000 CBA Fixed plant 50,000 CBA Goodwill 1,250,000 CBA? Investments 150,000 CA Other net assets 250,000 Total value 2,000,000 < 20% thus trading company
Old Goodwill Bloggs Trading Ltd Business premises 300,000 CBA Fixed plant 50,000 CBA Goodwill 1,250,000 CBA 1,600,000 Investments 150,000 CA Total chargeable assets 1,750,000 S165 holdover restricted to 91.4% If 40,000 then 3,439 chargeable (< annual exemption)
New Goodwill Bloggs Trading Ltd Business premises 300,000 CBA Fixed plant 50,000 CBA 350,000 Investments 150,000 CA Total chargeable assets 500,000 S165 holdover restricted to just 70% If 40,000 gain = 12,000 chargeable
S260 TCGA gift relief Gift of any asset where there is immediate IHT charge Lifetime transfer to all trusts now If < 325,000 then no IHT (< nil band) Also transfers out of trust Planning opportunity?
Passing on a Buy to Let using a trust S260 TCGA hold over gain where there is IHT charge e.g. transfer into and out of trust Simple planning technique Example Dad wants to give daughter 300K investment property. Base cost 60K CG = major deterrent Gain = 240,000 28% CGT = 67,200
Passing on a Buy to Let property Simple planning technique Dad transfers property into trust = if immediately chargeable = CG holdover (s260 TCGA) IHT charge? likely to be within nil rate band ( 325K) Property into trust for daughter without tax charge No CGT, no IHT
Passing on a Buy to Let Property Simple planning technique Property in trust If trust is felt to be inappropriate Wait at least 3 months. Or if trust suits, for longer but less than 10 years Appoint out property to daughter Holdover under s260 TCGA on way out No CGT If gifted directly no holdover = CGT for Dad
Self-settlement anti-avoidance S165 and s260 hold over denied Where transfer to settlor interested trust (= Settlor, spouse or minor child now) Relief also clawed back if becomes settlor interested Within 6 years of end of tax year of transfer
CGT and gifts between spouses H W at no gain/ no loss No gain on transfer banked IA if before 6.4.08 Up to end of year of separation 11,100 annual exemption each 10,000,000 Entrepreneurs Relief each
Rollover relief Replacement of business assets
Rollover relief Replacement of business assets Reinvest proceeds from old asset within period 1 yr before to 3 yrs after disposal Gain either held over or deferred Depends upon type of asset
Rollover relief 1.4.15 1.4.16 1.4.19 12M 36M BUY NEW ASSET SELL OLD ASSET
Rollover relief - qualifying assets Land and buildings *Goodwill Fixed plant & machinery Ships, aircraft, hovercraft Satellites and space craft!! *Quotas *Entitlement to farm payments
Depreciating assets Expected life < 60 years E.G. Leasehold premises Gain on old asset merely deferred Deferred until earlier of Sale of asset Cease using asset in trade 10 years after acquisition
CGT on incorporation
CGT on incorporation Mr Jones Mr Jones TRADE AND ASSETS SOLD TO A LTD Jones Ltd DR ASSETS CR LOAN A/C USE MV TO COMPUTE GAINS
Goodwill on Incorporation Mr Jones Mr Jones Jones Ltd TRADE AND GOODWILL SOLD TO JONES LTD DR G/WILL 1million CR LOAN A/C 1 million
Goodwill What we used top be able to do Incorporate business 30 November 2014 Sell goodwill to Jones Ltd leaving balance outstanding on loan account Gain on goodwill 1,000,000 With entrepreneurs relief just 10% CGT = 100,000 Can then withdraw loan account tax free If post 1.4. 2002 goodwill could even claim a CT deduction say 10 years = 100,000
Goodwill Autumn Statement Mr Jones Mr Jones Jones Ltd TRADE AND GOODWILL SOLD TO JONES LTD DR G/WILL 1,000,000 CR LOAN A/C 1,000,000 ****CGT Entrepreneurs Relief no longer available from 3 December 2014 ****
Goodwill CT deduction also blocked Sole trader/ Partnership to Ltd company Related parties Thus no write off of OLD goodwill (pre 1.4.2002) *** Can no longer write off if transferred from 3 December 2014 onwards ***
Incorporation CGT reliefs still available Small goodwill gains covered by 11,300 annual exemption then 10%/20% S165 gift of business assets Hold gain over into cost of assets Assets have low base cost Use if property to be retained personally S162 transfer of a business in exchange for shares Hold gains into base cost of shares Assets at market value No gain if asset sold shortly after
Goodwill on incorporation - back on? Worth considering selling goodwill again now CGT rate only 20%? Share of goodwill valued at 1,000,000 Transfer to Ltd company 30 June 2016 CGT due 31 January 2018 = 200,000 1,000,000 credit to loan account Net cost 800,000 No CT deduction for goodwill amortisation Say 10 years = 100,000 p.a. disallowed Sufficient profits to pay dividends?
Run Rental Business through a company? From 6 April 2017 buy to let interest restricted Companies will still receive interest relief against rental and other profits Income and gains taxed at 20% => 17% Indexation available against gains Double taxation taxed again when extract profit 5,000 dividend allowance Long term? No CGT or IHT relief on shares
Run Rental Business through a company? Transfer existing rental business to company? CGT properties transferred at MV + SDLT Hold over gain using s162 TCGA 1992 Transfer of business in exchange for shares Gain held over into base cost of shares Is it a business? Mr and Mrs E M Ramsay v HMRC (UTT) 20 hours a week running rental business - YES
s162 incorporation relief is it a business? Ramsey v HMRC UKUTT S162 TCGA holdover applies on transfer of a business Does not have to be a trade Gains held over into base cost of new shares issued Property rental business transferred 10 flats FTT agreed with HMRC that not operated as a business! 20 hours a week arranging maintenance, collecting rent, cleaning between lets Wrong decision? Overturned at UTT
Entrepreneurs Relief 10% CGT on first 10,000,000 gains now
Disposal of business assets Disposal of all or part of a business Disposal of shares in or securities of a company, or Disposal of assets following cessation of a business (3 years) (NB C16 striking off now gone must liquidate now)
Entrepreneurs Relief Trading Liquidation 4 YEARS 1 YEAR Entrepreneur relief on capital distribution if within 3 years
Entrepreneurs relief Shares and Securities Shareholder conditions: Officer or employee 5% of shares and voting rights Company conditions: Trading company Min 1 year
Entrepreneur s Relief - associated disposal Asset used by partnership or personal company Relief available where disposal results from disposal of all or part of the business or shares AND Withdrawal from the business Just and reasonable apportionment of gain eligible if charge rent
Withdrawal from Business HMRC guidance CG63995 Associated disposal and material disposal of business assets linked Relief not due unless the disposal is related to the individual s reduction of his interest in the assets of the partnership or holding in the company From 18.3.2015 must dispose of at least 5% of shares or partnership interest
Entrepreneurs Relief Castledine case Mr C held 5% of company s ordinary shares The company had also issued a number of deferred shares no rights to dividends, no votes, limited rights to capital on a winding up = worthless Should these shares be considered as ordinary share capital? If so Mr C only had 4.9% Held: deferred shares are ordinary shares Issued for a genuine commercial purpose As < 5% held by Mr C no entrepreneurs relief
Entrepreneurs Relief McQuillan case Mr and Mrs McQ each held 33% of company s ordinary shares (total 100) The company had also issued 30,000 redeemable nonvoting shares representing a loan to company No voting rights, no dividend rights, redeemable at par Should these shares be considered as ordinary share capital? If so Mr and Mrs McQ held <1% FTT: the redeemable shares not ordinary shares UTT: consider all shares unless have fixed return No entrepreneurs relief
Entrepreneurs relief Shares and Securities Shareholder conditions: Officer or employee 5% of shares and voting rights Company conditions: Trading company Min 1 year
Entrepreneurs Relief Not officer/employee J K Moore v HMRC (2016) UKFTT Purchase by company of own shares Mr Moore owned 3,000 out of 10,000 shares Fell out with other directors benefit company trade to buy back 2,700 his shares (90% reduction) 300/7,300 after buy back (4.1%) = CGT But entrepreneurs relief? - NO Resigned as director 28 February 2009 Special resolution for buy back 29 May 2009
Associated disposal? MR BLOGGS BLOGGS LTD
Company distributions CGT or IT? 52
HMRC Guidance on Winding up TAAR Sections 35 in Finance Act 2016 - introduced Targeted Anti- Avoidance Rule ITTOIA 2005 section S396B and s404a Certain distributions on a winding up taxed as income not CGT = up to 38.1% rather than 10% Applies to transactions from 6 April 2016 New HMRC Manual Guidance - CTM36300
Liquidations taxed as income if: A close company is wound up and an individual (S) with a material interest (5%) receives proceeds from the shares Within two years of that distribution S (or a connected person) continues to be, or becomes, involved in a similar trade or activity; and One of the main purposes of the winding up is to obtain a tax advantage Note successor could be unincorporated business
Company distributions Company Liquidation previously taxed as Gain = 10% with entrepreneurs relief Where income accumulated in company may now be taxed as income? Finance Act 2016 Profits 1,000,000 Less corporation tax 20% (200,000) Retained profit 800,000 CGT @ 10% (80,000) Net cash to shareholder 720,000 28% tax Dividends taxed at 7.5%,32.5%, 38.1% now
Company liquidations if income If distributed as a dividend: Profits 1,000,000 Less corporation tax 20% (200,000) Retained profit 800,000 IT @ 38.1% (AR) (304,800) Net cash to shareholder 495,200 50.48% tax
Similar trade or activity - example 2 Mrs F has been the sole shareholder of a company which carries on the trade of landscape gardening for ten years. Mrs F decides to wind up the business and retire. Because she no longer needs a company she liquidates the company and receives a distribution in a winding up. To subsidise her pension, Mrs F continues to do a small amount of gardening in his local village. Condition C similar trade or activity, BUT CGT treatment would not apply if arrangements do not appear to have tax as a main purpose (condition D)
Similar trade or activity - example 3 Mr E is a builder who runs his business through two companies Company 1 specialises in loft conversions, and Company 2 specialises in extensions. Mr E winds up Company 1, but the trade of Company 2 continues. As with Example 2, Mr E continues to be involved with a trade that is similar to that of the company that is wound up, and so Condition C is satisfied.
Continues to be involved in similar trade or activity Mrs C, an accountant runs her business through a company. Her husband is a self-employed lion tamer. Mrs C winds up her company and starts work for a newlyformed company owned by her husband, providing accountancy services. Mrs C continues to be involved with the same trade or activity as the wound-up company was involved with (the provision of accountancy services), even though she is now an employee rather than business owner. She is connected to her husband and so Condition C is met. Condition D will still need to be satisfied.
Condition D section 396B S396B applies Condition D where: it is reasonable to assume, having regard to all the circumstances, that 1. The main purpose, or one of the main purposes of the winding up is the avoidance or reduction of a charge to income tax, or 2. The winding up forms part of arrangements the main purpose or one of the main purposes of which is the avoidance or reduction of a charge to income tax
Factors HMRC will consider: Is there a tax advantage, and if so, is its size consistent with a decision to wind-up a company to obtain it? To what extent does the trade or activity carried on after the winding-up resemble the trade or activity carried on by the wound-up company? What is the involvement in that trade or activity by the individual who received the distribution? To what extent have their working practices changed? Are there any special circumstances? For example, is the individual merely supplying short-term consultancy to the new owners of the trade?
Factors HMRC will consider: How much influence did the person have over the arrangements? Is it a reasonable inference that arrangements were entered into to secure this advantage? Is there a pattern, for instance have previous companies with similar activities been wound-up? What other factors might be present to lead to a decision to wind-up? Are these commercial and independent of tax benefits? Any events linked with the winding-up that might reasonably be taken into account? For example, was the only trade sold to a third party, leaving just the proceeds of the sale?
Exclusions: Distribution does not create chargeable gain Repayment of base cost of shares Distribution of irredeemable shares/ Demergers Where shareholder receives shares in a new company and that new company receives all of the assets of the old. Although it is arguable that there is a tax advantage here, the chargeable gains legislation provides an exemption for reconstructions
EIS and Seed EIS and CGT planning
Tax breaks for EIS investor 30% income tax credit* Max 1,000,000 @ 30% Disposal CGT exempt* Deferral of gains * Provided not connected Capital loss relief v income
Qualifying Trading Company Carry on qualifying trade, or Parent co of trading group Unquoted (includes AIM) Gross assets 15m before issue (was 7m) 16m after issue (was 8m) SP2/00 - gross assets per B/Sheet
EIS - Qualifying Trades UK companies or those with UK PE (branch) Certain trades excluded (< 20%) : Dealing in land, shares, commodities, futures etc. Dealing in goods other than wholesale/ retail Banking, insurance, HP, financial Leasing, (royalties OK) Legal and accountancy
EIS Excluded activities: Property development Farming, market gardening Woodlands and forestry Operating/managing hotels Operating/managing nursing homes Companies receiving Feed In Tariffs Providing services for non-qualifying trade
EIS / Seed EIS Qualifying Individual Unconnected investor Not > 30% of share capital (with associates) Not an employee of company (nor associates) May become a director however New issue of shares for cash Retain shares for 3 years or relief clawed back Clawback if value received from company
Seed EIS Associates Spouse, parent, child or Remoter forebear or issue Trustees of settlement where individual (or above) settlor Not brother, sister, in-laws Business partner
Business Angels Investors may become paid directors and qualify Unless previously connected Or involved in carrying on any part of trade carried on by the company May make further investment within 3 years
Seed EIS relief made permanent Was to apply from 2012/13 for 5 years: 50% IT reducer up to 100,000 each tax year Plus CGT exemption on 50% of gains reinvested No CGT on disposal of shares (after 3 years) Total 150,000 investment per company Many rules based on EIS Unconnected investor New Qualifying trading company
Seed EIS Qualifying Company Newly incorporated company: < 2 years prior to issue of shares < 200,000 gross assets prior to share issue < 25 employees when shares issued In good financial health not company in difficulty? Unquoted companies only Must not be in partnership Carrying out qualifying business activity (as EIS) Max 150,000 share issue qualifies for relief
Making Seed EIS work for your clients Johnny starts a new software company Needs 20,000 for new computers, plant His aunty Betty has 20,000 in bank minimal interest She buys shares in nephew s company 10,000 income tax relief (50%) Gains up to 10,000 exempt No CGT on disposal of shares after 3 years Company goes bust set loss against income (s131)
New CGT investors relief New CGT relief for long term investors in unquoted trading companies, not directors, employees 10% CGT on first 10m of lifetime gains Must be new issue of shares for new consideration Issued on after 16 March 2016 Held for at least 3 years Anti-avoidance to ensure genuine commercial investment
Property disposals 20% instead of 28% CGT Reinvest the property gain in EIS company shares Defers the gain until the shares are sold Gain comes back into charge at the general rate of CGT, currently 20% for a higher rate taxpayer. No minimum holding period for EIS deferral relief (3 years for income tax relief and unconnected) The reinvestment must take place during the period of 12 months before to 36 months after the date of disposal of the property.
Property disposals 20% instead of 28% CGT Cliff sells property in November 2016 for 300,000 making a capital gain of 100,000. Reinvest the 100,000 gain in EIS shares Jan 2017. The 100,000 gain would be deferred until the EIS shares are sold and the 28,000 CGT not payable If unconnected deduct 30,000 (30%) IT liability Cliff sells the EIS shares in February 2020 for 105,000. 5,000 gain on the EIS shares exempt from CGT The 100,000 deferred gain comes back into charge at the general rate 20%, so just 20,000 CGT payable.
Inheritance Tax Refresher and Update
IHT Basics Tax on value of estate at death + Gifts within 7 years of death 40% tax after 325,000 => 2020 Conservative manifesto 1,000,000? Therefore give away and live for 7 years Enough to live on? What about the house?
IHT Basics Importance of Domicile UK domiciled IHT on worldwide assets Remain UK domiciled for 3 years if emigrate Non UK domiciled IHT on UK situs assets only Deemed UK domiciled for IHT if resident for 15 years Planning: Put Foreign assets into trust while non Domiciled Assets were Excluded Property No UK IHT Changed from 6 April 2017
Annual IHT Planning Exemptions what are there? Annual Wedding Normal expenditure (gifts out of income) Family Maintenance Charity Watch interspouse if one non dom (now 325K) Watch interaction between chargeable gifts and PETs = 14 year planning?
Exempt transfers -lifetime only Annual exemption - 3,000 Small gifts - 250 Marriage exemption Parents - each 5,000 Grandparents, remoter 2,500 Spouses 2,500 Others 1,000 Normal expenditure out of income
Gifts out of income THREE CONDITIONS - S21(1) IHTA 84 Part of the normal expenditure of transferor (Taking one year with another) it was made out of his income Was left with sufficient income to maintain his normal standard of living
36% IHT if leave 10% to charity Applies to deaths after 6 April 2012: 36% IHT rate if bequeath >10% of estate to charity 10% of estate after exemptions, reliefs, NRB Add back charitable legacy = 10% of baseline amount Example: George, single man, dies leaving estate 2,325,000 after exemptions and reliefs
IHT charity bequest example No charitable bequest: IHT payable 2,000,000 @ 40% = 800,000 Net estate 1,200,000 (+ 325,000) 200,000 left to charity: IHT payable 1,800,000 @ 36% = 648,000 Net estate 1,152,000 (+ 325,000) 200,000 bequest saves 152,000 tax (76%)
Lifetime gifts Potentially exempt transfers: Outright gift to individual to life tenant trust to 22.3.06 to A&M trust to 22.3.06 Other transfers chargeable at time of gift, E.g. Transfer to discretionary trust Most trusts from 22.3.06 Transfer of value by close company
Lifetime gifts PETS can be done very late in life for IHT Gifts within annual exemptions - 3,000 pa Over 10 years - couple can give away 66,000 Watch CGT on gifts not if cash Hold over? S165 or s260 TCGA Take gain if within 11,300 AE
Married couples & IHT nil band transfer From 9 October 2007 Unused nil band (%) from first spouses death transferred to survivor Utilised on second death No action required on first death Claimed by LPR on second death
Nil band transfer example Dad dies January 2008 All of estate left to Mum, no lifetime gifts Nil band used = 0%, balance 100% Mum dies 2015, nil band 325,000 Mum gets 200% = 650,000 nil band
Nil band transfer example Dad died October 2007 Nil Band 300,000 100,000 to children, balance to Mum Nil band used = 1/3, balance 2/3 Mum dies 2025, say nil band 360,000 Mum gets 166.7% = 600,000 nil band
Additional Main Residence Nil Rate Band Additional 175,000 IHT relief for family home No IHT on transfer of family home < 1,000,000 = ( 325,000 + 175,000) x 2 Also available if downsize Like NRB transferred to surviving spouse if unused Taper relief by 1 for 2 over 2,000,000 before IHT reliefs e.g. BPR, APR May need to review client s Will s and estate planning
IHT Family Home Allowance Additional IHT relief for family home, phased in: 100,000 2017/18 125,000 2018/19 150,000 2019/20 175,000 2020/21 Then increased with CPI
IHT Family Home Allowance - tapering Taper relief by 1 for 2 over 2,000,000 before IHT reliefs e.g. BPR, APR Family home 900,000, business worth 5m would mean no Family Home relief! Couple with 2m home plus 1m savings owned jointly = 1,500,000 Leave half share to spouse on first death On second death, estate = 3m, no relief
Residence Nil Rate Band - Downsizing Additional NRB available if downsize: 1. to a less valuable residence and that residence, together with assets of an equivalent value to the lost RNRB, has been left to direct descendants, or 2. sold their only residence, and the sale proceeds, or assets of an equivalent value, have been left to direct descendants, or 3. has otherwise ceased to own their only residence, and other assets of an equivalent value have been left to direct descendants
RNRB Downsizing Conditions Individual dies on or after 6 April 2017 The property disposed of must have been owned by the individual and it would have qualified for the RNRB had the individual retained it Less valuable property, or other assets of an equivalent value if the property has been disposed of, are in the deceased s estate Less valuable property, and any other assets of an equivalent value, are inherited by the individual s direct descendants on that person s death
RNRB Downsizing Further Conditions Downsizing or the disposal occurs after 8 July 2015 No time limit on the period in which the downsizing or the disposals took place before death Any number of downsizing moves between 8 July 2015 and the date of death of the individual Would also include disposing of part of a property (including land occupied and used as a garden or grounds) or a share in it Where a property is given away, assets of an equivalent value to the value of the property when the gift was made must be left to direct descendants
Business and Agricultural Property Relief
Business property 100% on unquoted shares + AIM 50% for control of quoted co. 100% on partnership interest, sole trader 50% on assets used in company (controlled) or partnership Not investment, dealing cos IRC v George, Farmer Own relevant property for 2 years
Agricultural Property Relief 100% relief against agricultural value, where: Occupied for agricultural purposes throughout 2 years prior to transfer (owner/ farmer) Owned by him throughout a period of 7 years ending with that date has been occupied throughout that period (by him or another) for agricultural purposes. Must have right to vacant possession within 2 years Now applies to all new agricultural tenancies from 1995 If above does not apply then only 50% APR
Business property (APR) - danger areas Relief denied if binding contract for sale Lifetime gifts Asset must still be owned by donee at donor s death Must qualify for BPR/APR at death Excepted assets cash? Barclays Bank Trust Co Assets used by family company?
Own property personally - BPR? MR BLOGGS BLOGGS LTD
Business property (APR) - danger areas Relief denied if binding contract for sale Lifetime gifts Asset must still be owned by donee at donor s death Must qualify for BPR/APR at death Excepted assets cash? Barclays Bank Trust Co Assets used by family company?
The End Any Questions?