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25/03/2009
The IHT legislation is built around the concept of what is a ‘transfer of value’ The main charging provisions state that a charge to IHT can only arise if there has been a ‘chargeable transfer’, which is a transfer of value which is made by an individual that is not an exempt transfer.
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Should a lay trustee whose co-trustee was the Executor and Trust Company of a solicitor’s firm be entitled to argue that he had a reasonable excuse for the late payment of capital gains tax (CGT) on a share sale because HMRC had not drawn the payment on account feature to his attention?
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