Commentary

I3.751 Lease carve-out schemes (Ingram schemes)

IHT, trusts and estates

I3.751 Lease carve-out schemes (Ingram schemes)

I3.751 Lease carve-out schemes (Ingram schemes)

A typical example of a lease carve-out scheme is where:

  1.  

    •     Mr A transfers title to his property to a nominee

  2.  

    •     the nominee then grants Mr A a 20-year lease of the property at a peppercorn rent

  3.  

    •     the encumbered freehold reversion is then gifted to Mr A's son, and

  4.  

    •     Mr A continues to occupy the property

Such schemes were found to be effective in Ingram1 and speedily rendered ineffective (as regards real property) by FA 1986, ss 102A–102C for gifts of interests in land made after 8 April 1999 (see I3.401A, I3.407).

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial