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Home / Simons-Taxes /IHT, trusts and estates /Part I4 Transfers on death /Division I4.2 Exemptions and reliefs on death /Partial exemption and attribution / I4.238 Attribution where there are tax-free and subject to tax gifts (double grossing)
Commentary

I4.238 Attribution where there are tax-free and subject to tax gifts (double grossing)

IHT, trusts and estates

Specific gifts not bearing their own tax may not be the only gifts with respect to which the transfer is chargeable, for example, there may be other chargeable specific gifts which do bear their own tax, or residue or a share of it may be chargeable.

The rate at which specific gifts not bearing their own tax should be grossed up must take account of the existence of these other chargeable gifts. This is achieved by a

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