Historical IHT schemes: Ingram and reversionary lease schemes

Produced by Tolley in association with Charlotte Kynaston

Trusts and Inheritance Tax

Guidance

The family home is often the largest asset in the estate and is frequently an obstacle to effective estate planning.

The simplest approach is usually for the client to sell their home and downsize to a smaller property. They can make use of principal private residence relief for capital gains tax (CGT) and release funds to make potentially exempt transfers (PETs) for inheritance tax (IHT) purposes. See the Outright gifts guidance note.

However, many clients want to remain living in their home until their death. In this case, it will be difficult to give away the home without getting caught by the gift with reservation (GWR) of benefit provisions or the pre-owned asset tax (POAT). During the 1990s and early 2000s, a number of schemes and arrangements were devised to help clients avoid these provisions and still remain living in the home.

See the Gifts with reservation ― overview and Pre-owned assets tax (POAT) guidance notes.

The introduction of the transferable nil rate band in 2007 rendered

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Charlotte Kynaston

Barrister at Ten Old Square Chambers

Charlotte is a member of Ten Old Square Chambers. She has a general Chancery practice, with a focus on non-contentious private client matters.She has particular experience in advising on trusts and associated taxation, wills, probate and the administration of estates. She is adept at drafting deeds and other trust documents.Charlotte recently spent six months seconded to the private client department of a major City law firm. Whilst there, she advised on the full spectrum of private client practice. She gained particular expertise in international private client taxation, trust administration and probate matters.Charlotte was awarded a first class degree in History from the Queen's College at the University of Oxford. She went on to gain a Distinction in the Graduate Diploma in Law and an Outstanding in the Bar Professional Training Course. She was awarded the Benefactors' Prize by the Queen's College and a Major Scholarship from the Inner Temple.She is a member of the Chancery Bar Association, a committee member of the Junior Chancery Bar Association and an associate member of STEP.

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Historical IHT schemes: Ingram and reversionary lease schemes