Historical IHT schemes: Ingram and reversionary lease schemes

Produced by Tolley in association with Charlotte Kynaston
Trusts and Inheritance Tax
Guidance

Historical IHT schemes: Ingram and reversionary lease schemes

Produced by Tolley in association with Charlotte Kynaston
Trusts and Inheritance Tax
Guidance
imgtext

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+™
Charlotte Kynaston
Charlotte Kynaston linkedinicon

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.

Powered by Tolley+
  • 09 Dec 2025 10:10

Popular Articles

Transfer of assets to beneficiaries ― legal, administration and tax issues

Transfer of assets to beneficiaries ― legal, administration and tax issuesThis guidance note outlines how assets are transferred to beneficiaries and the tax consequences that flow from the transfer. Whether a payment is income or capital is discussed in the Payments to trust beneficiaries guidance

14 Jul 2020 13:52 | Produced by Tolley Read more Read more

What are connected companies for loan relationship purposes ― practical approach

What are connected companies for loan relationship purposes ― practical approachBrief overview of the rulesThe loan relationships legislation applies to any ‘money debt’ arising from the lending of money entered into by a company, either as a lender or borrower. The rules are contained in CTA 2009,

20 Apr 2021 16:00 | Produced by Tolley Read more Read more

Classes of NIC and who pays them

Classes of NIC and who pays themClass 1 NICClass 1 NIC is payable on earnings paid to an employed worker which derive from, or are treated as deriving from, an employed earner’s employment in the UK. There are two kinds of Class 1 NIC, primary contributions for which the employee is liable and

Read more Read more