Commentary

I5.702 General rule for IHT treatment of reversionary interests

IHT, trusts and estates

I5.702 General rule for IHT treatment of reversionary interests

I5.702 General rule for IHT treatment of reversionary interests

In general, subject to the exceptions set out in I5.724–I5.728, a reversionary interest is excluded property1. Thus:

  1.  

    (a)     For the purposes of determining whether a lifetime disposition causes a diminution in the value of the transferor's estate, and therefore whether he has made a transfer of value2, no account is taken of the value of a reversionary interest which is excluded property and ceases to form part of the transferor's estate as a result of the disposition3

  2.  

    (b)     If a person dies beneficially entitled to such a reversionary interest it does not form part of his estate (for IHT purposes only) immediately before his death4 and so is

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