Claim for Loss Relief on sale of land - time limit

Is it me, or is HMRC’s IHT38 form incorrect?

I have just been researching on the potential for a claim on loss on sale of land which I felt had various complications in any event, due to appropriation of the majority of it, sale to a father etc.

On checking S.191 IHTA 1984 the time limit for a sale seems to be 3 years to me unless I am missing some update to the legislation but all sources I have looked at say there are no updates outstanding.

(1) Where—

(a) an interest in land is comprised in a person’s estate immediately before his death and is sold by the appropriate person within the period of three years immediately following the date of the death, and

(b) the appropriate person makes a claim under this Chapter stating the capacity in which he makes it,

the value for the purposes of this Act of that interest and of any other interest in land comprised in that estate and sold within that period by the person making the claim acting in the same capacity shall, subject to the following provisions of this Chapter, be its sale value.

[(1A) A claim under this Chapter must be made not more than 4 years after the end of the period mentioned in subsection (1)(a).]

HMRC’s own tax manual seems to agree with this.

So, my understanding is that the sale (exchange) must be within 3 years of death, and the claim must be within 4 years of the end of that period, i.e. 7 years.

BUT page 1 of Form IHT38 states:

To qualify for relief the sale must have been made within 4 years of the date of death and a claim submitted 7 years from the date of death.

All views welcome, but it seems to me that either I am missing some update to the legislation, or HMRC’s own Claim form is wrong !

My sale is over 3 years from death.

Thank you

Tracy

See s 197A. See s 197A.

Said twice as posts must be of at least 20 characters.

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Bravo, Duncan. Avoidance par excellence! We may see the Forum’s rules altered to incorporate a TAAR or a GAAR or DOTAS aimed at word avoidance by, implausibly, using more of them.

There is another rule that you cannot make 3 consecutive posts, not even to correct an error or add a thought. With my being nothing if not prolix and paranoid I am inclined to take this prohibition personally.

Jack Harper

Dear Jack,

Re:

I have now changed the maximum consecutive reply limit from 3 to 5. (This limit does not apply to the topic creator, who can reply as many times as they like).

Kind regards,
Tom

Dear Duncan,

Re:

I have now reduced the minimum allowed post (reply) length in characters from 20 to 10.

Kind regards,
Tom

Thank you on behalf of Spartans everywhere.

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Is the time of a sale in the IHTA 1984 on exchange of contracts or on completion?

Thank you Duncan for putting me right and pointing me at the right clause.

Sorry my acknowledgement is somewhat late, when I last tried to get on the Forum I was having difficulties.

I am surprised that there isn’t some cross-reference in the legislation so that you can find the ‘fourth year’ rule as it does not immediately follow the three year clause but I guess that is how it goes.

Thanks again.

Regards

Tracy