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HMRC internal manual

Capital Gains Manual

Death of person with interest in possession: valuation of trust assets

The basis of valuation of land for Inheritance Tax on death of a life tenant may differfrom the basis of valuation of (i) above, but it is considered that TCGA92/S274, seeCG32210+, does not apply because the disposal under Section 72(1) is of a notional assetwhich exists only in the terms of Section 72(5).