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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Death of person with interest in possession in part: special traetment

In some circumstances a strict construction of the words `corresponding part’ also makesfor complicated calculations of `cost’ of a composite nature. Accordingly, where aninterest in possession in a part of settled property ends in circumstances which give riseto a deemed disposal, the trustees may indicate that the ‘corresponding part’ consists ofparticular assets, provided that either

  1. the part of the settled property in which the interest terminates can be identified with specific assets in the fund

or

  1. they appropriate specific assets to give effect to the termination within a reasonable time (see CG36481) of its happening

and

in either case the treatment is not inconsistent with that adopted for IHT purposes.