The deceased had made certain inheritance tax planning arrangements which involved the assignment of the reversionary interest of the reversionary beneficiary in MTrust (a 150-year Isle of Man trust) to the deceased, who was then granted an option to become the income beneficiary of the MTrust. Prior to the exercise of the option, the deceased transferred his reversionary interest to the KTrustees in 2010 (prior to the enactment of s74A-C Finance Act 2012).
HMRC issued two notices of determination under s221 of the Inheritance Act 1984 against the executors of th...
Five shareholders of Taskcatch plc made gifts of shares in the company to various charities and then claimed tax relief on the basis of the value of such shares at the dates of the gifts. Mr Dwan gifted 500,000 shares on 31 March 2003 and claimed relief on the basis of their value being 32.5p per share. On 31 March 2003, a small trade of shares in Taskcatch plc was registered on AIM at a price of 32.5p per share. Also on 31 March 2003, shares in Taskcatch plc were issued at the implied price of 7p per share to the vendors of a company that was being acquired. On 5 October 2004, Mr and Mr...
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