Kersner v HMRC [2019] UKFTT 221 (TC)

WTLR Issue: Autumn 2019 #176

On an appeal against HMRC’s determination of liability to inheritance tax the appellant made a number of applications in the First-Tier Tribunal (Tax Chamber), including an application to opt out of the complex track costs regime, and for disclosure of documents alleged to be relevant to the HMRC’s assessment that the appellant had not been domiciled in the UK, but in Israel, when shares had been transferred to her by her husband...

LCN v KF Neutral citation: [2019] EWCOP 1

WTLR Issue: Summer 2019 #175

CJF was a thirteen year old boy who suffered very serious neurological damage at birth. He was initially cared for by his mother, KJF, but she had also suffered complications as a result of CJF’s birth, so he ended up being cared for by a foster parent, LR under a Special Guardianship order...

Rogge v Rogge [2019] EWHC 1949 (Ch)

WTLR Issue: Winter 2019

The first and second claimants had four children, three of whom were the defendants. The third defendant suffered a serious brain injury while playing polo and was left unable to walk unaided. The first and second claimants purchased two contiguous flats in London, one for themselves and the other for the third defendant...

HMRC v Parry [2018] EWCA Civ 2266

WTLR Issue: Spring 2019 #174

Shortly before her death the director of a company (S) transferred the funds from a company pension policy acquired by her on her divorce from her ex-husband and known as a s32 buyout policy (the s32 policy) to a personal pension policy (PPP) issued by AXA...

PBC v JMA [2018] EWCOP 19

WTLR Issue: Winter 2019

This was an application by the applicant, PBC, the son and attorney under a lasting power of attorney of the patient, JMA, to authorise various gifts exceeding £7m in value. The purpose of the gifts was to achieve a reduction in inheritance tax (IHT) liability...

Ross v HMRC [2017] UKFTT 507 (TC)

WTLR Issue: 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...

Harris v HMRC [2018] UKFTT 204 (TC)

WTLR Issue: Spring 2018 #171

HMRC successfully applied to strike out Mr Harris’ appeal against an inheritance tax determination, under Rule 8 of the Tribunal Procedure (First-Tier Tribunal) (Tax Chamber) Rules 2009.
 Mr Hughes was appointed as Administrator of the deceased’s estate in June 2013...

Palliser v HMRC [2018] UKUT 71 (LC)

WTLR Issue: Spring 2018 #171

The appellant, Mr Palliser, disputed the valuation, for inheritance tax purposes, of a property in which his father’s estate owned an 88.4% share in the long leasehold and a third of the freehold title of the building it which it is located. HMRC had determined that the market value of the estate’s share at the date of the deceased’s death was £1,829,880...

Routier v HMRC [2017] EWCA Civ 1584

WTLR Issue: Autumn 2017 #169

The appeal concerned the restriction (the Restriction) imposed by s23 of the Inheritance Tax Act 1984 (IHTA), as interpreted by the Court of Appeal in an earlier hearing of the appeal, on IHT relief for legacies and gifts to charities, to legacies and gifts to UK charities subject to the supervision of the UK courts...