Related Commentary  Related HMRC Manuals

174(1)  In determining the value of a person’s estate immediately before his death, allowance shall be made for–

(a)any liability for income tax in respect of an offshore income gain, within the meaning of regulations under section 354(1) of the Taxation (International and Other Provisions) Act 2010, arising on a disposal which is deemed, under such regulations (see regulation 34 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001)), to occur on the death; and

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