Losses
When a beneficiary becomes absolutely entitled to settled property as against the trustee, the assets to which he becomes so entitled are deemed to be disposed of at market value by the trustee, in his capacity as trustee under the settlement, and to be immediately reacquired by him, also at market value, in the different capacity of bare trustee for the beneficiary who is absolutely entitled1 — see I5.1017. Accordingly, at that time the beneficiary is deemed to have acquired the assets for a consideration equal to market value2.
If the deemed disposal gives rise to an allowable loss, that loss is first set
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 17:32