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The IHTA84/S180 restriction applies to a purchase made at any time between the date of death and two months after the date of the last sale.聽 During this period s.180 and IHTA84/S185 can both apply if the appropriate person (IHTM34161):

• buys investments of the same description as qualifying investments in the death estate, and
• subsequently sells part of the resulting combined holding.

Example

On the death of Josie the life tenant, the Pluto trust fund includes 10,000 shares in JKL plc.聽 Their date of death value is 拢2 per share.聽 A few months later the trustees buy a further 5,000 shares for 拢7,000, at 拢1.40 per share.聽 Following this purchase the trustees have 15,000 shares.聽 Later, but within the year, the trustees sell 9,000 shares at 拢1.50 per share.

Under s185, the shares sold have to be apportioned (IHTM34193).聽 The number of shares that are treated as being from the death estate is:

10,000 梅 15,000 x 9,000 = 6,000

The date of death value of these shares is 6,000 x 拢2.00聽聽 =聽聽 拢12,000

The sale proceeds of these shares is 6,000 x 拢1.50聽聽聽聽聽聽聽聽聽聽 =聽聽聽聽 拢9,000聽聽

On this basis, the loss on sale is聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽聽 聽聽聽聽聽聽聽聽聽=聽聽聽聽 拢3,000.

S.180 then applies to reduce the loss of 拢3,000 by the formula (IHTM34183) in IHTA84/S183 (5).聽 In this case the aggregate value of the sales is the sale proceeds of the 6,000 shares treated as being from the death estate and the loss relief is reduced by:

7,000 梅 9,000 x 拢3,000 = 拢2,333

The net loss is now 拢3,000 - 拢2,333聽 = 拢677.