I am acting in relation to an estate whereby the deceased made lifetime gifts to individuals in Uganda (exceeding the value of the NRB). The gifts were to individuals, thereby not qualifying for charitable exemption. The value of the gifts exceeded his annual income. Is it possible to present an argument to HMRC that a % could be said to have been out of income- any advice as to how to present this would be most welcome. Secondly, does anyone have experience in tracing gifts to Uganda made to individuals when administering an estate- if so please could they share their experience.
Swinburne Maddison LLP