Buzzoni and Others v HM Revenue and Customs – FTC/57-59/2011: UTTC 19 Oct 2012

UTTC Whether s. 102(1)(b) of the Finance Act 1986 (gift with reservation) applies to a gift of a reversionary underlease containing covenants from the donee mirroring covenants in the donor’s head lease. Application of Ingram v. IRC. Decision of the First-tier Tribunal upheld: such covenants do constitute a reservation within the section.

Citations:

[2012] UKUT 360 (TCC)

Links:

Bailii

Statutes:

Finance Act 1986 102(1)(b)

Jurisdiction:

England and Wales

Citing:

Appeal from – Buzzoni and Others v Revenue and Customs FTTTx 21-Apr-2011
FTTTx INHERITANCE TAX – grant of future underlease – covenants reserved – whether donor excluded or virtually excluded – appeal dismissed . .

Cited by:

Appeal from – Buzzoni and Others v Revenue and Customs, Re The Estate of Lia Kamhi (Deceased)) CA 19-Dec-2013
. .
Lists of cited by and citing cases may be incomplete.

Inheritance Tax, Landlord and Tenant

Updated: 10 November 2022; Ref: scu.466700