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Partnership land

23 August 2011
Issue: 4318 / Categories: Forum & Feedback , Inheritance Tax
What is the general tax position where a partner introduces land into a partnership to mitigate future inheritance tax liabilities?

Whether business land and property is owned personally by a partner and used in his partnership or is a partnership asset will determine whether business property relief is available at 50% or 100%.

The basis of ownership will also have an impact on what assets the individual has in his estate for will purposes etc.

I am aware that partnership land capital accounts can be used where the property is shown on the partnership balance sheet with an associated capital account balance being allocated to the relevant partner.

I am unsure as to what the tax position and general legal position is with this type of arrangement. If there is a partnership where the whole value of the business premises and any future profit on their disposal is allocated to a single partner who owns the premises and...

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