H and W were in partnership. H dies, his share being subject to a life interest for W, subject to that on discretionary trusts.
BPR would have been available on H’s partnership interest. There was no partnership agreement and so the partnership will have determined on death.
W continues the business after death as a sole trader in the same premises, which were a partnership asset.
Would the combined effect of s106-109 IHTA (replacements and successions/successive transfers) mean that if the trustees appointed out H’s share of the former partnership assets to the children before 2 years after H’s death, 100% BPR would be available,
and CGT holdover relief?