Inheritance Tax - Planning

Below is a selection of our most recent updates on this subject.

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Pre-Owned Assets Guidance 6 Available On The HMRC Website

HMRC has updated its guidance about pre-owned assets and home loan schemes as explained in the HMRC Trusts and Estates Newsletter December 2011.
Monday, February 06, 2012

Calculating The Discount On A Dgt

A recent decision by the First-tier Tribunal has considered the principles that should apply in calculating the value of the discount when somebody invests in a Discounted Gift Trust.
Thursday, January 19, 2012

Gift With Reservation Of Benefit Under A Reversionary Lease

In Buzzoni v HMRC (2011) UKFTT 267 (TC) the creation of a reversionary underlease failed to achieve the desired inheritance tax benefit because of a reservation of benefit. So decided the First Tier Tribunal (Tax)
Wednesday, August 10, 2011

Withdrawals From Single Premium Bonds And The Normal Expenditure Out Of Income Exemption.

Whether it is possible to take account of withdrawals from a single premium bond in determining a person's income for the purposes of the normal expenditure out of income exemption.
Monday, July 25, 2011

Taxpayer Claiming Income Tax Loss From A Double Trust Loan Scheme Loses Appeal

In Audley v HMRC (2011) UKFTT 219 the First-tier Tribunal (Tax) decided, taking a purposive interpretation of the legislation and a realistic view of the facts, that the terms of a loan note were artificial, the settlor made a gift and the only purpose in the trustees issuing the loan note was to sustain a loss that would be eligible for income tax relief. In the circumstances the claim for loss relief was denied.
Tuesday, June 14, 2011

The Obvious Problem With Secret Trusts: The Evidence (Lack Of)

In the case Davies and Rippon v HMRC [2009] UKFTT 138 (TC) the First-tier Tribunal (Tax) rejected the appeal from the deceased's two daughters who claimed that the property they inherited was property settled by the late father and held subject to a secret trust.
Friday, June 10, 2011

Rysaffe Trust-Based Planning

The danger in relying on the (apparently, relatively benign) related settlement provisions when planning to minimise the level of future periodic charges
Wednesday, April 20, 2011

The Extension Of The Disclosure Rules To Inheritance Tax.

HMRC provides guidance on when the disclosure of an inheritance tax scheme will be required.
Friday, April 15, 2011

HMRC Changes Their Guidance On Certain Lifetime Schemes Involving A Loan

In October 2010 HMRC updated section 5 of their Pre-Owned Assets Guidance in relation to lifetime 'double trusts/home loan' schemes.
Friday, December 31, 2010

Valuing Assets On Death - IHT Guidance

HMRC has recently amended their guidance on valuing land and buildings for inheritance tax purposes.
Tuesday, December 14, 2010

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