New queries, issue 4527

Company and shops

Inheritance tax and capital gains tax on property used by a family company.

I act for a successful company and of the 100 ordinary shares 99 are owned by a father (aged 69) and one by his son who is now the managing director of the company. It is a trading company selling furniture and there is also a daughter who works in the company but who is not a shareholder or director.

The father also owns two shops and a warehouse that are used exclusively for the company’s business and for which it pays him rent.

Assuming that the father dies first the inheritance tax business property relief for the warehouse and shops will be restricted to 50% and I would like to consider a transfer to the children. My questions are as follows.

First would...