Commentary

I3.317 Deemed PETs—GWRs and Phizackerley transactions

IHT, trusts and estates

I3.317 Deemed PETs—GWRs and Phizackerley transactions

I3.317 Deemed PETs—GWRs and Phizackerley transactions

Where a gift with reservation has been made and the reservation ceased before death, there is deemed to have been a potentially exempt transfer (PET) made by him when the reservation ceased. This is essentially machinery for charging the ending of the reservation to tax rather than a further category of PET. See, further, I3.435.

Where someone repays all or part of a debt which, by virtue of FA 1986, s 103, would not have been deductible in determining the value of his estate for the purposes of the tax charge on

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