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HMRC internal manual

Capital Gains Manual

Life interests: extension to non-life interests: example

The settled property consisted of three assets, put in trust in 1975, which were held bythe trustees on the death of X in 1983. X had an interest in possession which was not alife interest.

Asset 1 was sold in April 1984 to meet the Capital Transfer Tax liability on X’s death andthe chargeable gain was assessed and settled in 1985.

Asset 2 was land. It was sold in March 1990. The disposal was returned and an estimatedassessment raised in October 1990, and tax paid. However the valuation at 31 March 1982was disputed and therefore the assessment was still open on 15 February 1993.

Asset 3 was sold on 16 February 1993

The concession applies to Asset 2 and Asset 3 but not to Asset 1.