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Readers’ forum: How should company shares held in trust be valued?

16 October 2023
Issue: 4909 / Categories: Forum & Feedback , Inheritance Tax
Exposure to inheritance tax

I am trying to determine a client’s exposure to IHT.

The client is the life tenant of three interest in possession trusts all settled at different times by different family members. They are all qualifying interest in possessions (either by virtue of being settled pre March 2006 or by being immediate post death interests). Therefore the assets of all the trusts are deemed to form part of the client’s estate for IHT purposes.

Each trust owns shares (directly or indirectly) in an investment company. Trust 1 owns A ordinary shares in the company. Trust 2 owns B ordinary shares in the company. Trust 3 owns shares in a holding company whose only asset is A ordinary shares in the company.

How should these shares be valued in the client’s estate? Are any of the shareholdings aggregated together when valuing the trusts’ respective holdings or are these holdings valued...

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