I4.431 Distributions within two years of death—the basics
IHTA 1984, s 144(1) applies where property comprised in a person's estate has been settled by his Will and, within two years of his death, an event occurs which would otherwise have given rise to an exit charge on that property under the relevant property rules (see Division I5.3).
The term 'distribution'
The term 'distribution' is used here and in I4.432–I4.435 to refer to any event which is an occasion of charge on relevant property. An event which happens under the provisions of the Will rather than by an exercise of a power can equally fall within IHTA 1984, s 144.
In relation to the estate of a testator who dies after 21 March 2006, s 144(1) is excluded from applying only if, since the testator's death, there has been an immediate post-death interest (IPDI — see I5.205) in possession in the settled property or a disabled person's
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