Attribution of values to specific investments: example of how values are revised under IHTA84/S187(3)
At the date of death the deceased owned qualifying investments in four companies, Ash, Beech, Cedar and Elm plc. The personal representatives sold all the shares within 12 months of the death. The values on death and at the date of sale, together with the losses or gains made are shown below
|Qualifying investments||Value on death||Sale value||Gain/(loss)|
|2,000 shares in Ash||£2,000||£1,600||(£400)|
|1,500 shares in Beech||£2,200||£2,400||£200|
|1,000 shares in Cedar||£5,000||£4,000||(£1,000)|
|500 shares in Elm||£2,000||£2,000||Nil|
The personal representatives purchased £5,000 of qualifying investments in the period between the date of death and two months after the date of the last sale.
Because of IHTA84/S180 the loss on sale is reduced by the relevant proportion (IHTM34212)
(£5,000 ÷ £10,000) x £1,200 = £600
The loss on sale relief is therefore reduced to £600 (£1,200 - £600).
The revised value of the shares in Ash is £1,600 plus an amount equal to the relevant proportion of the difference between the value on death and the sale price,
which is £1,600 + [(£5,000÷£10,000) x £400] = £1,800.
The revised value of the shares in Beech is £2,400 less an amount equal to the relevant proportion of the difference between their value on death and the sale price,
which is £2,400 – [(£5,000÷£10,000) x £200] = £2,300.
The revised value of the shares in Cedar is £4,500, calculated in a similar way as for A.
There is no change in the sale price for Elm.