[IHTM14314] Lifetime transfers: gifts with reservation (GWRs): the gift: examples of the property given – carve-out arrangements
The following are examples to help you ascertain the property given in different scenarios:
Example of a leasehold carve-out arrangement
In 1998 Aarif gave his residence to his daughter, Yasmin. Yasmin subsequently leased the residence back to Aarif at less than the full market rent. Yasmin was not under a legal or equitable obligation to do this.
This is a gift with reservation (GWR). The property disposed of was the unencumbered freehold. The lease is a reserved benefit which infringes the conditions of FA86/S102(1)(b).
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