IHT: Hoodwinked?

Luke Busbridge outlines a case that provides a reminder of the rules on reservation of benefit ‘The executors argued that because the covenants given in the sub-lease were intrinsically bound up in Lady Hood’s gift in the first place, it was impossible to separate them out in the way that HMRC had done.’ Viscount Hood …
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Cases Referenced

  • Buzzoni & ors v HMRC [2013] EWCA Civ 1684; [2014] WTLR 421 CA
  • Commissioner for Stamp Duties of New South Wales v Perpetual Trustee Company Ltd [1943] UKPC 20
  • Hood v HMRC [2017] WTLR 999
  • In re Nichols [1975] 1 WLR 534
  • Ingram & anor v IRC [1998] UKHL 47
  • St Aubyn v Attorney-General [1951] UKHL 3
  • Viscount Hood (executor of the estate of Lady Hood) v HMRC [2018] EWCA Civ 2405