Luke Busbridge outlines a case that provides a reminder of the rules on reservation of benefit ‘The executors argued that because the covenants given in the sub-lease were intrinsically bound up in Lady Hood’s gift in the first place, it was impossible to separate them out in the way that HMRC had done.’ Viscount Hood …
Continue reading "IHT: Hoodwinked?"
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Wills & Trusts Law Reports | Autumn 2017 #169Lady Hood was the lessee of premises at 67 and 67A Chelsea Square, London SW3 (premises) which had been granted by Viscount Chelsea and Chelsea Land & Investment Company Ltd and Cadogan Holdings Company (Cadogan) on 21 September 1979 for a term due to expire on 25 December 2076 (head lease). By licence granted by Cadogan a reversionary sub lease of the premises was granted by Lady Hood to her sons on 19 June 1997 to commence on 25 March 2012 and to expire on 22 December 2076 (sub lease). Lady Hood as sub-lessor and her sons as sub-lessees respectively covenanted to perform and observ...
Jennifer Emms considers the outcome of schemes used to reduce IHT on the family home and outlines best practice ‘While I understand the legal distinction that has been drawn between the Hood case and Buzzoni, the practical result seems to be somewhat arbitrary.’ I am a fan of all things sweet, in particular, cake, whether …
Continue reading "Succession Planning: Having your cake?"
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Mary Ashley gives an update on the long-running case of Buzzoni v HMRC ‘Buzzoni provided a rare opportunity for the Court of Appeal to clarify how the gifts with reservation rules apply.’ The reservation of benefit rules in relation to inheritance tax (IHT) have always been a hiccup in the planning context. This has led …
Continue reading "Gifts With Reservation: A win for the taxpayer"
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