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

Continue reading the full document

To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™

TAKE A FREE TRIAL NOW

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.

Popular Articles

Owner-Managed Businesses

Tax implications of administration and liquidation

Tax implications of administration and liquidationThis guidance considers the tax implications of a company going into administration or liquidation.Introduction to company administration and liquidationCompany going into administrationA company which is in financial difficulty may go into

14 Jul 2020 15:29 | Produced by Tolley Read more

Personal Tax

Self assessment ― amendments and corrections

Self assessment ― amendments and correctionsOnce a self assessment tax return has been filed, both HMRC and the taxpayer (or the agent) has the right to make changes to the return. There are different time limits depending on whether it is a correction by HMRC or an amendment made by the

14 Jul 2020 13:37 | Produced by Tolley Read more

Corporation Tax

Withholding tax

Withholding taxIntroductionUK tax must be withheld on UK payments including:•interest•royalties•rental incomeUK withholding tax may be reduced under the provisions of a double tax treaty (DTT). Prior to 1 June 2021, payments of interest and royalties made to EU resident associated companies were

14 Jul 2020 14:01 | Produced by Tolley Read more

Historical IHT schemes: Ingram and reversionary lease schemes