Commentary

I3.558 Double charges relief—mutual gifts (CLTs)

IHT, trusts and estates

I3.558 Double charges relief—mutual gifts (CLTs)

I3.558 Double charges relief—mutual gifts (CLTs)

To prevent IHT being paid twice on the same value where a transferor has received back property that he has given away, relief is given in some circumstances by the IHT (Double Charges Relief) Regulations1. This article is about reg 7, which concerns transactions such as the following. After 17 March 1986 A transfers property to T1 and T2, as trustees of a discretionary settlement under which A is a beneficiary. The property (or property directly or indirectly representing it) is later distributed to him by the trustees. He dies within seven years of

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