Apart from the related property rules, questions arise regarding the extent to which property, particularly unquoted shares, is aggregable for valuation purposes.
This article also considers the principles that arise when parcels of land or different share categories need to be combined or split.
Aggregation of settled property
One aspect of aggregation is the principle1 that a person's estate is the sum of all the property to which he is beneficially entitled — this is fully discussed I8.370.
Gift with a reservation
If a person dies while there is property subject to a reservation of which he was the donor (see I3.401) it is treated as part of his estate immediately before his death2 (see I3.436), but property subject to a reservation is not treated as part of the donor's estate at other times. For the purposes of the charge on death, therefore, property subject to a reservation may also be aggregated with absolute or beneficiary-taxed interest in possession property in the same estate, or with related property,
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