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Dear Sir,
In this MCQ Kristine gave share worth 150,000 to a trust on 15/09/08 and she died on 23/10/17. then this shares should be exempted as it is before 7 years of death.
but in answer it is included and deducted in nil rate band ? Why ?
Please explain
The transfer is a CLT, not a PET so although THAT transfer will not be chargeable again on death, for as you say the taxpayer survived for the required 7 years, it was chargeable in lifetime and will still be deemed to have utilised the NRB for any transfers that fall within 7 years of it (to 15/09/15) and which are chargeable on death as THEY do arise within the 7 years of death.
This is dealt with in section 9 of chapter 24 of the OT notes and in the example that follows that note
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