Hood v Revenue and Customs: FTTTx 2 Feb 2016

Inheritance Tax : Gifts – – deceased granted reversionary sub-lease to sons out of her head leasehold interest – licence to sub-let given by head landlord to deceased – sub-lease provided for same covenants, including repairing covenants, as in head lease – whether property disposed of by way of gift was subject to a reservation under s 102 FA 1986 – application of second limb of s 102(1)(b) – identification of donated property – whether benefit ‘trenched upon’ donees’ enjoyment of the donated property – Buzzoni considered

[2016] UKFTT 59 (TC), [2016] SFTD 351, [2016] STI 1159, [2016] WTLR 835
England and Wales

Inheritance Tax

Updated: 10 January 2022; Ref: scu.559927