A person's estate which, according to IHTA 1984, s. 4(1), is deemed to be transferred immediately before death, is defined in s. 5(1), as follows:

‘For the purposes of this Act a person's estate is the aggregate of all the property to which he is beneficially entitled, except that

(a)the estate of a person

(i)does not include an interest in possession to which section 71A or section 71D below applies, and

(ii)does not include an interest in possession that falls within subsection (1A) below, and

(b)the estate of a person immediately before his death does not include excluded property.’

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