Client puts a property into trust with a gain of £150,000. Hold-over relief is claimed. Subsequently the property appreciates £50,000 in value and is transferred out of trust to a beneficiary, and again hold-over relief is claimed, on the gain held-out. The beneficiary subsequently lives in the property for 7 years and then dies. Is it correct that because of s226A no PPR is available at all, or does PPR apply for the 7 years during which the beneficiary was owner and occupier?
I Will Solicitors Ltd