UUÂãÁÄÖ±²¥

Historical IHT schemes: Ingram and reversionary lease schemes

Produced by Tolley in association with
Trusts and Inheritance Tax
Guidance

Historical IHT schemes: Ingram and reversionary lease schemes

Produced by Tolley in association with
Trusts and Inheritance Tax
Guidance
imgtext

The family home is often the largest asset in the estate and is frequently an obstacle to effective estate planning.

The simplest approach is usually for the client to sell their home and downsize to a smaller property. They can make use of principal private residence relief for capital gains tax and release funds to make potentially exempt transfers (PETs) for IHT purposes. See the Outright gifts guidance note.

However, many clients want to remain living in their home until their death. In this case, it will be difficult to give away the home without getting caught by the gift with reservation (GWR) of benefit provisions or the pre-owned asset tax (POAT). During the 1990s and early 2000s, a number of schemes and arrangements were devised to avoid these provisions and still remain living in the home.

See the Gifts with reservation ― overview and Pre-owned assets tax (POAT) guidance notes.

The introduction of the transferable nil rate band in 2007 rendered such planning for lower value estates

Access this article and thousands of others like it
free for 7 days with a trial of Tolley+™ Guidance.

Charlotte Kynaston
Charlotte Kynaston

Barrister at Ten Old Square Chambers


Charlotte is a member of Ten Old Square Chambers. She has a general Chancery practice, with a focus on non-contentious private client matters.   She has particular experience in advising on trusts and associated taxation, wills, probate and the administration of estates. She is adept at drafting deeds and other trust documents.   Charlotte recently spent six months seconded to the private client department of a major City law firm. Whilst there, she advised on the full spectrum of private client practice. She gained particular expertise in international private client taxation, trust administration and probate matters.   Charlotte was awarded a first class degree in History from the Queen's College at the University of Oxford. She went on to gain a Distinction in the Graduate Diploma in Law and an Outstanding in the Bar Professional Training Course. She was awarded the Benefactors' Prize by the Queen's College and a Major Scholarship from the Inner Temple.   She is a member of the Chancery Bar Association, a committee member of the Junior Chancery Bar Association and an associate member of STEP.

Powered by
  • 25 Sep 2023 10:40

Popular Articles

Wholly and exclusively

Wholly and exclusivelyFor both income tax and corporation tax purposes, one of the fundamental conditions that must be satisfied for an item of expenditure to be deductible, is that it must incurred ‘wholly and exclusively’ for the purposes of the trade, profession or vocation. References to CTA

14 Jul 2020 14:00 | Produced by Tolley Read more Read more

Self assessment ― estimates and provisional figures

Self assessment ― estimates and provisional figuresIf the taxpayer does not have sufficient information to enable them to complete the tax return in the time allowed, they should include either a best estimate or a provisional figure. The taxpayer should not either leave a box blank or enter

14 Jul 2020 13:37 | Produced by Tolley Read more Read more

Furnished holiday lets

Furnished holiday letsThis guidance note sets out the qualifying conditions for a property let to be treated as a furnished holiday let (FHL) for tax purposes and the subsequent tax implications.Whether or not a property qualifies as an FHL can make an important difference to the taxation

14 Jul 2020 11:46 | Produced by Tolley Read more Read more