hypothetical question on who has the inheritance tax liability

mrjoneill

Pat dies intestate he was not married and had no issue but has 2 brothers Peter and Frank. Peter dies 6mts after Pat and also dies intestate. Peter has children.
Who is liable for the inheritance tax from the beneficial interest from what Peter acquired from Pat?

Mr. Incognito

Pats estate and whoever is administering the estate regardless of the beneficiaries

mrjoneill

What I really want to know on this is will Peters beneficial interest be assessed for inheritance tax although he is deceased or can it be leapfrogged over him to Peters family or will revenue be seeking a double payment from the Peter estate and from his issue.

NCG

Peter's estate is liable on his benefit. It would be nice if the benefit could leapfrog down as you would then often have more than one group threshold to use against the same benefit (2 children in your case). Unfortunately there is no provision for this though. It is even more unfair if he died before the valuation date and never having had any beneficial use of the property involved (as in a current case I am dealing with), but that's the way it is.