IHTM28102 | Liabilities: investigating liabilities: Canadian income tax

Following a review of HMRC’s interpretation of IHTA84/S159(1), the position regarding Canadian income tax has been updated. It was previously thought that Canadian income tax on a deemed disposal on death should be treated in the same way as any other income tax liability and allowed as a deduction against the value of property in Canada. HMRC now believes that unilateral relief may be available under IHTA84/S159(1) in respect of Canadian income tax charged on deemed disposals immediately before an individual’s death. IHTM27181 and IHTM27185 onwards explain further about unilateral relief.

Any claims involving Canadian income tax should be referred to Technical.