Executors of the estate of Linington & anr v Commissioners for HMRC [2023] WTLR 917
Wills & Trusts Law Reports | Autumn 2023 #192The deceased had made certain inheritance tax planning arrangements which involved the assignment of the reversionary interest of the reversionary beneficiary in MTrust (a 150-year Isle of Man trust) to the deceased, who was then granted an option to become the income beneficiary of the MTrust. Prior to the exercise of the option, the deceased transferred his reversionary interest to the KTrustees in 2010 (prior to the enactment of s74A-C Finance Act 2012).
HMRC issued two notices of determination under s221 of the Inheritance Act 1984 against the executors of th...
JP Gilchrist Trust v HMRC Case number: FTC/89/2012
Wills & Trusts Law Reports | September 2014 #142Mr Gilchrist settled property on trust on 17 May 1993. Under the terms of the trust, he was entitled to a life interest in the trust property. On 4 June 1993, the trustees exercised an overriding power of appointment to appoint 20% of the fund (the appointed fund) out of the main fund, on discretionary trust for the benefit of members of Mr Gilchrist’s family. Mr Gilchrist and his spouse were excluded from any benefit in the discretionary trust. Mr Gilchrist then gifted £44,000 to the trustees. The trustees used the funds to contribute to Whitecroft Limited, in which the trust held...