[HMRC Tax Bulletin 9, November 1993]

Under Section 102 Finance Act 1986, any property given away on or after 18 March 1986 subject to a reservation is, on the death of the donor, treated as forming part of the donor’s estate immediately before his death. Gifts with reservation (GWRs) are defined as gifts where either:

the donee does not assume bona fide possession and enjoyment of the property at the date of the gift or 7 years before the donor’s death, if later; or

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