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HMRC internal manual

Inheritance Tax Manual

Government securities in foreign ownership: type of security and ownership

If a government security is a FOTRA gilt (IHTM04291) you will have to consider who is beneficially entitled (IHTM04031) to that security to work out whether it is excluded property for IHT purposes.

If a worthwhile amount of tax is at stake you should investigate the possibility of a last-minute purchase. Except where the available information (e.g. inclusion of sufficient income/interest) reasonably rules out that possibility, you should seek specific confirmation that the gilts concerned were in fact registered in the transferor’s, or the trustee’s, name(s) at the date of the relevant transfer.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)