Commentary

I12.307 Reversions under settlements

IHT, trusts and estates

I12.307 Reversions under settlements

I12.307 Reversions under settlements

Where a settlor disposes of property by way of settlement but retains for himself a reversionary interest, whether vested or contingent, the possible application of the reservation of benefit principle is discussed in detail at I3.401A, I3.407. Generally speaking, the retention of a reversionary interest does not constitute a benefit reserved in respect of the property given away, but is a distinct, severable interest retained by the donor and not included in the gift itself. The Revenue have accepted that a settlor's the retention of a reversionary interest under a trust will not constitute a reservation

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