Commentary

I12.418 Eversden schemes

IHT, trusts and estates

I12.418 Eversden schemes

I12.418 Eversden schemes

The steps involved in a typical Eversden type arrangement are considered at I12.309. Sch 15 will apply to such arrangements because:

  1.  

    (i)     the chargeable person continues to occupy the land (thus fulfilling the requirement in paragraph 3(1)(a)); and

  2.  

    (ii)     the gift of the property to the trustees 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.

It will be noted that the exclusion contained in FA 2004, Sch 15, para 10(1)(c) will not apply

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