Where the deceased was a partner and the partnership owned
land, whether the deceased had an interest in the partnership land
for the purposes of IHTA84/S190 (1) depends on whether the deceased
was a beneficial owner of a share of the partnership assets
including the land. You should refer any such case to TG.
In Scotland individual partners will not be entitled to
beneficial ownership in the partnership heritage as such, the
partnership being a separate legal persona. But where the
circumstances are such that on a reasonable view it appears that
the deceased might be regarded as entitled to the underlying
interest in partnership land which is subsequently sold, you should
refer the case to TG.
