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HMRC internal manual

Capital Gains Manual

Conversion of securities: compensation stock: devolution on death

A devolution on death is not treated as a disposal, see CG12605 and, therefore, cannot release the held over gain. A later disposal of the gilts by the person who acquired them by devolution on death does not release the held over gain. In effect the held over gain is lost. The reference to a disposal by personal representatives to legatees in TCGA92/S134 (4) covers the situation in which the nationalisation occurs after the date of death while the original shares are in the hands of the personal representatives.