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IHT400 Needed?

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I am dealing with probate for my late mother's estate and would appreciate confirmation, or otherwise, that I need to submit an IHT400. No IHT is due - most of the estate is passing to my father. My mother had approx. £324k in a managed ISA. Of the constituent funds roughly 1/3 are held in Ireland and Luxembourg. Are these deemed to be foreign assets? If so then I will need to submit an IHT400 as the value at date of death of these was £102.5k.

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