Curtis Green v HMRC [2015] UKFTT 0236 (TC)

Wills & Trusts Law Reports | October 2015 # 153

Mrs Green ran a business known as Flagstaff Holidays (the business) which let five units of self-contained holiday accommodation in a property known as Flagstaff House, Burnham Overy Staithe, King’s Lynn, Norfolk (the property). Mrs Green had bought the property for £900,000 in 2003. Between 2009-2012, the property was let for a total of around 650 to 750 nights a year. At all relevant times, Mrs Green lived in Woodbridge, Suffolk. On 2 February 2010, the property was valued by a firm of estate agents at £1.9m on a vacant possession basis.

On 5 April 2010, Mrs Green settled ...

Best v HMRC

Wills & Trusts Law Reports | April 2014 #138

The appellant was the executor of Alfred Buller. On Mr Buller’s death there was a transfer of value of 25,000 shares in Bullick Developments (1986) Ltd (the company). The company owned and managed the Valley Business Centre (the business centre). HMRC determined pursuant to s221 Inheritance Tax Act 1985 (the IHTA 1985) that the shares in the company were not relevant business property for the purposes of s104 IHTA 1984, having regard to s105(3) IHTA 1984, which prevents inter alia shares in a business whose activities mainly or wholly consist of ...

Business Property Relief: Scrutiny of services

The result of the Pawson appeal has done little to clarify the criteria for claiming BPR in the case of furnished holiday lettings, as Matthew Woods and Sophie Carter relate ‘It was understood that HMRC were awaiting the outcome of this decision before issuing determinations on a number of other claims for business property relief …
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Business Property Relief: Scrutiny of services

The result of the Pawson appeal has done little to clarify the criteria for claiming BPR in the case of furnished holiday lettings, as Matthew Woods and Sophie Carter relate Interpretation of an intelligent businessman versed on all the available law begins to sound like a tribunal judge, rather than the man on the Clapham …
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McCall & anr v HMRCC [2009] NICA 12

Wills & Trusts Law Reports | December 2011 #115

The appellants were the personal representatives of Mrs Eileen McClean (the deceased), who died on 8 January 1999. The appellants claimed that 33 acres of agricultural land in the deceased’s estate, which at the date of the deceased’s death was valued at £5.8m, owing to it having been zoned for development use, was business property for inheritance tax (IHT) purposes. The respondent, HMRC, determined that no part of the value of the agricultural land transferred on death was attributable to the value of any relevant business property.

The land comprised a number of fields in grass...