Tax: Taking it over the line

Firth sheds light on the inheritance tax treatment of furnished holiday lettings. Dr Christopher McNall discusses the case The key issue is whether property is ‘relevant business property’, so as to qualify for BPR, or simply part of the business of holding land, being ‘wholly or mainly… making or holding investments’. Business property relief (BPR) is …
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APR and BPR: Attention to detail

Christopher McNall analyses a recent First-tier Tribunal judgment that demonstrates the importance of thorough evidence in cases where the bases for reliefs are tested ‘The key issue, upon which the tribunal focused, was whether there existed “a functional connectivity” between Mr Gill’s occupation of the house and the agricultural activities that took place on the …
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Executors of the estate of Ross v HMRC [2018] WTLR 1417

Wills & Trusts Law Reports | Winter 2018 #170

Mrs Ross originally owned a hotel called the Port Gaverne Inn in Cornwall and later acquired eight holiday cottages across the road called the Green Door Cottages. When she was no longer fit enough to run the business, the hotel was sold though its new owner agreed to provide services to guests renting out the cottages. A handyman was employed by the partnership which owned the cottages and other properties. When Mrs Ross died on 7 November 2011, she was entitled to a two-thirds share in the partnership and the total value of all the properties held by it amounted to £1.5m. The appellant...