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Property partnership

15 September 2009
Issue: 4223 / Categories: Forum & Feedback , Inheritance Tax
A married couple with a substantial residential property portfolio wish to mitigate their potential inheritance tax liability

A married couple for whom I act have been investing in residential investment property for many years. They now have a portfolio which is worth approximately £4 million with no borrowings attached.

The couple are both in their late 50s and have two grown-up children who are not involved in the business. They have also formed a limited company and have a small number of investment properties owned within the vehicle of this separate company also jointly owned by them.

We are now considering inheritance tax mitigation. A solicitor suggested the use of a family partnership with the parents as the shareholders of a corporate general partner and having sole responsibility for management. The parents children and any other beneficiaries are the other partners.

The lawyer has suggested that assets can be put into the partnership and equity shares in the partnership can be gifted to the...

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