The second part of IHTA84/S4 (1) quantifies the deemed transfer
by reference to the value of the deceased’s estate
immediately before death. This brings within the death charge the
whole of the deceased’s beneficial estate (
IHTM04029) as defined in IHTA84/S5 (1),
including settled property in which he had an interest in
IHTM16000) and any GWR (
IHTM14301) property, but excluding
excluded property. (IHTM04251) It also means that general
provisions governing the value of a person’s estate apply,
for example, IHTA84/S5 (3) (allowance for liabilities).
The reference to the value immediately before death is subject to IHTA84/S171 which largely allows changes in value caused by the death ( IHTM04046) to be taken into account.