Several years ago the 100% shareholder of a company died.
Under the terms of his will he left the shares to his son.
for a number of reasons the estate has taken many years to be wound up. The company has lent £100,000 to the son.
The shares are still owned by the executors.
I know that if it was a trust situation this would be caught be s455 but are executors treated the same a trustees?
Who would pay the suffer the tax if the loan was written off? would it be the PR's or the son?
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