I am dealing with a trust which has now come to an end following the death of life tenant created pre 1974 where surviving spouse was the life tenant and estate duty paid on the first spouse to die. Can you help as to the implication as regards CGT; is it still a non chargeable notional disposal with a rebasing of acquisition costs to the date of death of the life tenant? I am aware that the trust is not aggregateded to the free estate ( treated as excluded property) but can find no guidance on the CGT position.
It’s a while since I dealt with a case like that, but as far as I can recall the assets ( certainly in the case of Quoted shares) acquire a new base value for CGT at the date of death of the life tenant even though no, IHT arose. Although it does not specifically, you may find SVM107140 Helpful.
Thank you Patrick - that’s very helpful.