We act for a UK trading company that has a valuable trade and a property investment business.
The company is owned by UK resident foreign domiciled individuals. HMRC Clearance has been sought and received to undertake a s.110 reconstruction and effectively hive-off the property business. In the event the trading company were ever to be sold, it should be possible to now do this with a significantly reduced tax liability (in fact, at virtually a nil rate of tax). The property business has now been restructured in such a manner that it should have no further exposure to IHT.