Chargeable lifetime transfer

Where an individual makes a chargeable lifetime gift, such as a transfer into a discretionary trust, his cumulative total prior to the latest gift consists of chargeable transfers which he has made during the past seven years.

If the transferor dies within seven years after making the chargeable gift, extra tax is payable. In calculating the extra tax, the transferor's cumulative total must be adjusted to include potentially exempt transfers made before the chargeable gift and within seven years before death. For illustrative calculations, see ¶611-900.

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