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Home / Simons-Taxes /IHT, trusts and estates /Part I9 Foreign element /Division I9.4 Locality (situs) of assets for IHT /Situs of equitable interests for IHT / I9.435 Situs of reversionary interests for IHT
Commentary

I9.435 Situs of reversionary interests for IHT

IHT, trusts and estates

Reversionary interests are regarded as choses in action situated in the country where they are properly enforceable, ie where the trustees are1.

An equitable interest by subrogation under an insurance contract to sue for the loss of the goods was a chose in action situated in the country where the interest was properly enforceable.2.

HMRC states that the locality of a reversionary interest will normally

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