[2011] UKFTT 267 (TC)

[The appeal against this decision is reported at [2012] BTC 1,727.]

Mrs B Mosedale (Tribunal Judge) (Chairman), Mr J Stafford (Tribunal Member)

Decision released 21 April 2011

Inheritance tax – gifts with reservation – future underlease – Finance Act 1986, s. 102

  A disposal by way of gift of a future underlease was subject to a reservation of benefit within s. 102 of the Finance Act 1986 with the result that the gifted property was, for inheritance tax purposes, treated as property to which the deceased was beneficially entitled immediately before her death.


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