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Farmer (Farmer’s Executors) v IRC

Tax Planning for Farm and Land Diversification

Julie Butler (FCA)
Bloomsbury Professional
Publication Date:
Law Stated At:
11 July 2023
Chapter 13: Planning the best use of APR and BPR for inheritance tax Considering the position ‘in the round’ The facts and issue of the case Evidence presented by the taxpayer Structure of the farm History of the farm Facts and history surrounding the lettings Contents of the business accounts Probate values Arguments put forward by the executors Arguments put forward by HMRC Reasons behind the decision Factors surrounding definition of ‘the business consists’ Authority given by the case of Farmer Factors relevant to the decision The decision and the way forward ...

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