IHT is not really an issue - father-in-law's estate never remotely approached the nil rate band threshold - and the family were never looking for an uplift of their CGT cost to the value of the property at the time that father died.
HMIT/DV seem to accept that - under the provisions of s274 TCGA92 -if father had died in 1993 and the value of the property had been ascertained at £60000 for IHT purposes then our clients' CGT acquisition cost would also be £60000 in total - £30000 each. However they maintain that as the value was not so ascertained then the disposal value for the donor (not really important as of course the property was his home) does not necessarily have to match the acquisition cost of the donees.
My answers
Further thoughts
Thank you for these thoughts.
IHT is not really an issue - father-in-law's estate never remotely approached the nil rate band threshold - and the family were never looking for an uplift of their CGT cost to the value of the property at the time that father died.
HMIT/DV seem to accept that - under the provisions of s274 TCGA92 -if father had died in 1993 and the value of the property had been ascertained at £60000 for IHT purposes then our clients' CGT acquisition cost would also be £60000 in total - £30000 each. However they maintain that as the value was not so ascertained then the disposal value for the donor (not really important as of course the property was his home) does not necessarily have to match the acquisition cost of the donees.