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IHT avoidance scheme fails as covenants in sub-lease gift to sons reserved benefit (Viscount Hood (executor of the estate of Diana, Lady Hood deceased) v Revenue and Customs Commissioners)

IHT avoidance scheme fails as covenants in sub-lease gift to sons reserved benefit (Viscount Hood (executor of the estate of Diana, Lady Hood deceased) v Revenue and Customs Commissioners)
Published on: 23 November 2018
Published by: LexisPSL
  • IHT avoidance scheme fails as covenants in sub-lease gift to sons reserved benefit (Viscount Hood (executor of the estate of Diana, Lady Hood deceased) v Revenue and Customs Commissioners)
  • What are the practical implications of the judgment?
  • What was the background?
  • What did the Court of Appeal decide?

Article summary

Private Client analysis: Michael Cash, partner at Penningtons Manches LLP, examines a Court of Appeal decision that the grant of a reversionary long sub-lease of a residential property by the deceased to her three sons was property subject to a reservation of benefit within the meaning of section 102 of the Finance Act 1986 (FA 1986). The property was therefore part of her estate at death for inheritance tax purposes. or take a trial to read the full analysis.

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