- 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?
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.
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