IHTM37093 - Example Notices of Determination: Unlisted shares

Inheritance Tax

Notice of Determination

Under Section 221, Inheritance Tax Act 1984

TO: Mr Andrew Bernard Carr date: 13 February 2021

c/o Arnold and Sons

27 Liver Place IHT ref: F123123/19A

LIVERPOOL Case Ref: CFS-987654

LP1 1AB

The Commissioners for His Majesty’s Revenue and Customs have determined -

In relation to

a) the Settlement made on 1 January 2016 by Mr Alan Bertram Carr as settlor and Mrs Carol Diane Carr, Andrew Bernard Carr and Graham Harold Castle as trustees;

b) the transfer on 1 January 2016 by Alan Bertram Carr of 500 £1 ordinary shares in Carr’s Caravan Site Ltd (“the Shares”).

That, having regard to the provisions of section 105(3) Inheritance Tax Act 1984, the Shares are not relevant business property for the purposes of section 104 of that Act as the business of the Company consists wholly or mainly of making or holding investments.

(Name of issuing officer)

For the Commissioners for His Majesty’s Revenue and Customs

Right of appeal

If you wish to appeal against this determination (or any part of it), you should within 30 days after service of this notice give notice of appeal in writing, specifying the grounds of appeal, to

[Name of issuing Officer]

WMBC

HM Revenue & Customs

BX9 1LH

You need to quote the case reference [CFS-xxxxxx] and the Inheritance Tax (IHT) reference shown above when writing to us at the above address. If you send any documents to us you must tell us if you want them returned as we may securely destroy them after 90 days

If you do not appeal the determination will be conclusive in accordance with Section 221(5) of the Inheritance Tax Act 1984.