Where the gift with reservation (GWR) is treated as part of the donor's Inheritance Tax death estate (IHTM30021) under FA 1986IHTA84/S102 (3), the liability provisions in IHTA84/S200 apply. In their application to GWRs (IHTM04071) within IHTA84/S102 (3) the persons liable are set out as follows:

persons liable for all IHTA84/S102 (3) charges

persons secondarily liable for IHTA84S200 (1)(a) property, which is mainly unsettled property

persons additionally liable for property comprised in a settlement immediately before the death.

### Property subject to charge ### Persons liable ### Authority
All IHTA84/S102 (3) charges whatever the property Any person in whom the property is vested, whether beneficially or otherwise.

Any beneficiary entitled to an interest in possession.

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