I3.257 'Back To Back' Arrangements

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Commentary

IHT, trusts and estates

Where the purchase of an annuity in conjunction with a life policy constitutes a transfer of value, the value transferred is the lesser of:

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E4.507S Operation of the charge on securities with artificially enhanced market value

C1.106 Allowable capital losses

I7.323 APR and successions

D1.8101 Groups of companies

I4.142A Liabilities which are not discharged out of the estate

B5.123 BPS—negligible value claims

B5.820 Charity's profits of trade—general liability to income tax

I5.251 Absolute entitlement by the life tenant

D2.250 Group relief—limited rights, variable rights and options attaching to ordinary shares

C2.108 Contingent liabilities

E4.1146 The PAYE cumulative basis—overview

E1.1435 Appealing transactions in securities counteraction notices

B2.319 Duality of purpose—apportionment of the expenditure

C3.305 Rollover relief—time limit for acquisition of replacement assets

B5.846 Charities and close companies

I5.1212 Protector of a foreign trust

C2.1173 Interaction of the exemption election regime with other capital gains exemptions

E3.192 CGT loss relief on disposal of EIS shares

B2.202 Capital receipts

I5.1304 Beneficiary with contingent interest

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I3.257 'Back to back' arrangements

IHT, trusts and estates

E4.507S Operation of the charge on securities with artificially enhanced market value

C1.106 Allowable capital losses

I7.323 APR and successions

D1.8101 Groups of companies

I4.142A Liabilities which are not discharged out of the estate

B5.123 BPS—negligible value claims

B5.820 Charity's profits of trade—general liability to income tax

I5.251 Absolute entitlement by the life tenant

D2.250 Group relief—limited rights, variable rights and options attaching to ordinary shares

C2.108 Contingent liabilities

E4.1146 The PAYE cumulative basis—overview

E1.1435 Appealing transactions in securities counteraction notices

B2.319 Duality of purpose—apportionment of the expenditure

C3.305 Rollover relief—time limit for acquisition of replacement assets

B5.846 Charities and close companies

I5.1212 Protector of a foreign trust

C2.1173 Interaction of the exemption election regime with other capital gains exemptions

E3.192 CGT loss relief on disposal of EIS shares

B2.202 Capital receipts

I5.1304 Beneficiary with contingent interest

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I3.257 'Back to back' arrangements

IHT, trusts and estates

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