Commentary

I12.414 Practical implications—general

IHT, trusts and estates

I12.414 Practical implications—general

I12.414 Practical implications—general

It has been clear from the outset that the primary target of the legislation is the avoidance of the gifts with reservation provisions by the use of artificial schemes. The Inland Revenue's budget note issued at the time of the 2004 Budget contains the following passage:

'The Government is aware that various schemes designed to avoid inheritance tax have been marketed in recent years. These use artificial structures to avoid the existing rules about gifts made with reservation. As a result, people have been removing assets from their taxable estate but continuing to enjoy all the benefits of

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