Commentary

I12.305 Reversions following leases

IHT, trusts and estates

I12.305 Reversions following leases

I12.305 Reversions following leases

Lease carve out schemes were found to be effective in Ingram v IRC1 and speedily rendered ineffective (as regards real property) by the new FA 1986, ss 102A–C. Similar principles have been adopted in connection with gifts of chattels; planning on this basis continues to be effective for the purposes of the gifts with reservation legislation and was not caught by the alterations made to FA 1986 following the Ingram case. However, the leasehold interest retained by the donor under such schemes will from 6 April 2005 attract the application of the income tax charge on

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