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Carry on Varying
In Ralph Ray's article, 'Carry on Varying' (in Taxation, 9 May 2002), he highlights for practitioners certain issues relating to deeds of variation dated on or after 1 August 2002. In particular, he identifies that clients making such a deed also need to consider if a declaration for the purposes of section 142, Inheritance Tax Act 1984 and/or section 62(6), Taxation of Chargeable Gains Act 1992 should be included within it.
Carry on Varying
In Ralph Ray's article 'Carry on Varying' (in Taxation 9 May 2002) he highlights for practitioners certain issues relating to deeds of variation dated on or after 1 August 2002. In particular he identifies that clients making such a deed also need to consider if a declaration for the purposes of section 142 Inheritance Tax Act 1984 and/or section 62(6) Taxation of Chargeable Gains Act 1992 should be included within it.
There are in addition capital gains tax implications in that the beneficiary may be disposing of a chose in action. Where the benefit which is the subject of a variation is either in full or in part represented by an unadministered interest in an estate the deed will dispose of a chose in action. For capital gains tax purposes the...
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