Post by john ashbyIt strikes me that someone more knowledgeable then me (and I think I'm
looking at KRW) could make a decent presentation at the Academic Archers
conference on the impact of IHT for the Ambridge farms.
i am a little out of touch with current thinking.
Keri seems to think that Bodge Farm is a partnership involving Tony /
Pat / Tom / Helen and therefore whatever it is valued at 50% has already
been passed onto the younger generation and so only 50% is taxable on
the eventual demise of Pat'n'Tony and will therefore probably fall below
the threshold. Without knowing how the partnership was set up I cannot
comment BUI it was my understanding that the ownership of the land
remained with Pat'n'Tony and the partnership only related to the running
of the farm (you can legally distinguish the two). And there is the
added complication of Ambridge Organics brand name which name was used
to overcome ecoli which damaged the Bodge Farm name.
Brookfield is another tangled web. Here the complication is the
Philwill. Philwill gave equal shares to all 4 children in the event of
Brookfield being "sold". So does a legal company exist with 4 golden
shares? Or is it merely a trust of some description? In the Philwill
how does it envisage events on the death of (presumably) David - is that
a trigger to give the assigned value of the shares to the siblings?
Where does Roof sit in all of this? Has David made a will? What if a
sibling pre-deceases David - Kenton and Shula are older so if they drop
dead or get run over by a bus in Sunderland does that golden "share"
expire? Brookfield is large and valuable enough to be subject to IHT
but the legal position is unknown.
Home Farm is more complex - there were originally 13 shares held (I
think) as follows:
Biriyani: 3
ffffffer: 3
Adam: 2
Debbie: 2
Kate: 1
Alice: 1
Rugrat: 1
What happened on ffffffer's passing we have not been told (or at least
if we were I missed it) but I have to assume that they reverted to
Biriyani or potentially have been split equally between Adam / Debbie /
Kate / Alice - and possibly Rugrat as well {I think she would have
included him - others may have different views}.
The complication is that at one point in the farrago over chemicals
(which I never believed for one instant as he was never short of the
readies when he arrived) Biriyani made it clear that the land ownership
stayed with him but that it would be transferred later but there has
never been reference to that happening and it is clear that there are
sweetheart deals with Kate over land and Chris over at least one of the
cottages. Home Farm is way above the taxable limits and will struggle
to make the IHT payments.
All of which will be boring on air because accountancy is boring.
--
Kosmo Richard W
www.travelswmw.whitnet.uk
https://tinyurl.com/KRWpics