[IHTM04072] Lifetime transfers: the charging provisions for gifts with reservation of benefit
Reservation at the transferor's death
If the property (IHTM04030) gifted is subject to a reservation when the transferor dies, it is deemed to be property to which they were beneficially entitled (IHTM04031) immediately before their death (except to the extent that the property forms part of their estate anyway), FA86/S102 (3). So, the property is part of the transferor's estate, (IHTM04029) unless it is excluded property, (IHTM04251) and has to be valued at the date of death.
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