Delay in notifying the persons in whom property vests of a debt
due from them does not, of itself, preclude us from pursuing
settlement of the debt to the extent of the property received.
For example, unless we have accepted any payment in full
satisfaction of the final liability we are not precluded by
IHTA84/S240 (2) from pursuing a debt due from a person in whom the
property vests even though it may have been more than six years
after the distribution before they were notified of their
liability.
Similarly we are not precluded from pursuing a debt because
we failed to make timely use of information provided to us by the
taxpayer in respect of any interim distributions (ESCA19).
The presumption must be that the personal representatives (
IHTM05012) or trustees have retained
sufficient money to discharge their responsibilities or,
alternatively, they have made arrangements with the beneficiaries
for money to be reimbursed in the event of a shortfall.
(This text has been withheld because of exemptions in the
Freedom of Information Act 2000)