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...
AH v Greyco Ltd & anr [2021] WTLR 783
Wills & Trusts Law Reports | Autumn 2021 #184The applicant (Mr AH) sought the disclosure of trust instruments and trust accounts for the Blue Settlement and the Overseas Distributors Benefit Trust (ODBT), having been ordered to procure and disclose the same to Mrs AH in separate divorce proceedings being heard by the Family Court in England. The trustees of the Blue Settlement (Greyco) gave evidence that Mr AH was the settlor of the Blue Settlement, though both he and his family members were excluded as beneficiaries. The trustees of the ODBT (ABC) gave evidence that neither Mr AH nor his family members were within the class of ben...