Commentary

I12.417 Reversionary lease schemes

IHT, trusts and estates

I12.417 Reversionary lease schemes

I12.417 Reversionary lease schemes

The steps involved in this planning are considered at I12.309 above. The scheme will be caught by Sch 15 because:

  1.  

    (i)     the chargeable person continues to occupy the land (thus fulfilling the requirement in paragraph 3(1)(a)) by virtue of his retained freehold interest; and

  2.  

    (ii)     the gift of the reversionary leasehold interest to the donee satisfies the disposal condition; the chargeable person owned an interest in the relevant land after 17 March 1986 and has disposed of it otherwise than by an excluded transaction (a disposition which creates a new interest in land out of an

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