Commentary

I9.435 Reversionary interests

IHT, trusts and estates

I9.435 Reversionary interests

I9.435 Reversionary interests

Reversionary interests are regarded as choses in action situated in the country where they are properly enforceable, ie where the trustees are1. HMRC state that the locality of a reversionary interest will normally be determined by the residence of the trustees of the property to which the interest relates2.

There is clear authority for this view where the reversionary interest is under a settlement where there is a trust for sale3. Where there is no trust for sale, or one not recognised in the lex situs, there is no clear authority; the official view for estate duty

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