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Inheritance Tax And Property: Tread carefully
Guy Abrahams assesses Buzzoni v HMRC, which indicates the court’s current attitude towards reversionary lease schemes ‘If Mrs Kamhi had not been required by her landlord to obtain covenants from the tenant, and therefore been able to grant Ovalap a covenant-free underlease, it seems that the underlease would have achieved its intended purpose.’ The case …
Cases Referenced
Cases in bold have further reading - click to view related articles.
- Buzzoni v HMRC [2013] WTLR 47 UT (TCC)
- Ingram v Commissioners of Inland Revenue [1998] UKHL 47
- Oakes v Commissioner of Stamp Duties of New South Wales [1954] AC 57