LT TAX – Inheritance Tax – agricultural property relief – agricultural value – agricultural property – farmhouses – whether house occupied by ‘lifestyle’ farmer could be farmhouse – held bid of such person could not represent agricultural value – Inheritance Tax Act 1984 s 115(2) and (3)George Bartlett QC : ‘a farmhouse for the purposes … Continue reading Lloyds TSB Private Banking Plc (personal representative of Rosemary Antrobus deceased) v Inland Revenue (Capital Taxes); Re Cookhill Priory (No 2): LT 10 Oct 2005
Exempt transfer and relief- Agricultural property relief- farmhouse whether ‘character appropriate’ to 16.29 acres of agricultural land with adjacent agricultural buildings – Yes – farmed by deceased up to the date of his death – Inheritance Tax Act 1984 section 115 (2) relief granted. [2011] UKFTT 351 (TC), [2011] WTLR 1183 Bailii England and Wales … Continue reading Golding and Another v Revenue and Customs (Inheritance Tax : Agricultural Reliefs): FTTTx 18 May 2011
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The deceased had owned a site of 2.5 acres on which were built a large farmhouse, and other outbuildings. Held: The court identified the identify the three separate dimensions to the definition of agricultural property under the Act. The phrase ‘agricultural land’ in section 115(2) did not include buildings, and so the site could not … Continue reading Starke and another (Executors of Brown decd) v Inland Revenue Commissioners: CA 23 May 1995
Inheritance Tax Act 1984, s.115(2) – Agricultural relief – ‘Farmhouse’ Citations: [2002] UKSC SPC00337, [2002] STC (SCD) 483 Links: Bailii Statutes: Inheritance Tax Act 1984 115(2) Cited by: Cited – Lloyds TSB Private Banking Plc (personal representative of Rosemary Antrobus deceased) v Inland Revenue (Capital Taxes); Re Cookhill Priory (No 2) LT 10-Oct-2005 LT TAX … Continue reading Higginson (Executors of) v Inland Revenue: SCIT 3 Sep 2002
Mr Brown, the deceased, had owned a site on which was built a substantial farmhouse, with six bedrooms, and various outbuildings. The site formed part of a farm and the issue was whether the site was ‘agricultural land or pasture’ within the meaning of section 115(2). Held: A site with farm buildings only is not … Continue reading Starke and Another (Executors of Brown Deceased) v Inland Revenue Commissioners: ChD 24 Feb 1994
SCIT INHERITANCE TAX – agricultural property relief – freehold house which was owned and occupied by the deceased – agreed that it was a farmhouse – whether it was of a character appropriate to the property – yes – IHTA 1984 s 115(2).Miss Antrobus had lived in a substantial freehold house, surrounded by about 126 … Continue reading Lloyds TSB Bank Plc (Antrobus Deceased) v Inland Revenue (No 1): SCIT 17 Oct 2002
INHERITANCE TAX – deemed transfer on death – deceased’s estate included a farmhouse – whether the Appellant, who had been in occupation of the farmhouse at the date of the death and for some years prior thereto and had incurred expenditure on the farmhouse, had acquired an equitable interest in the farmhouse such as to … Continue reading Hanson v Revenue and Customs: FTTTx 31 Jan 2012
UTTTC INHERITANCE TAX – deemed transfer on death – deceased’s estate included a farmhouse – whether the farmhouse was agricultural property within section 115(2) Inheritance Tax Act 1984 – nature of the nexus required between a farmhouse and the agricultural land or pasture etc. in the definition – whether such nexus was occupation and ownership … Continue reading HM Revenue and Customs v Hanson (As Trustee of The William Hanson 1957 Settlement): UTTC 17 May 2013
FTTTx Inheritance tax – death – estate passing on death – was there settled property derived from deceased’s husband who died in 1969 and estate duty was paid – questions of secret trust and mutual wills – transitional relief from inheritance tax – Inheritance Tax Act 1984 Schedule 6, paragraph 2 Powell J [2009] UKFTT … Continue reading Davies and Another v Revenue and Customs: FTTTx 9 Jun 2009
References: [2013] UKUT 224 (TCC) Links: Bailii Coram: Warren J UTTTC INHERITANCE TAX – deemed transfer on death – deceased’s estate included a farmhouse – whether the farmhouse was agricultural property within section 115(2) Inheritance Tax Act 1984 – nature of the nexus required between a farmhouse and the agricultural land or pasture etc. in … Continue reading HM Revenue and Customs v Hanson (As Trustee of The William Hanson 1957 Settlement); UTTC 17 May 2013
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