Salinger & anr v HMRC [2016] UKFTT 677 (TC)
December 2016 #165Donald Paiba Salinger (deceased), who was domiciled in the UK, sought to reduce the inheritance tax burden which would arise on his death by acquiring a reversionary interest in an offshore trust on the basis that it would qualify as excluded property (s48(1) of the Inheritance Tax Act 1984) and then transfer that reversionary interest to the trustees of the Donald Salinger Family Trust (DSFT) on the basis that no loss to the estate would be caused and thus not constitute a transfer of value. These transactions took place before legislation designed to block similar tax...
Curtis Green v HMRC [2015] UKFTT 0236 (TC)
October 2015 # 153Mrs Green ran a business known as Flagstaff Holidays (the business) which let five units of self-contained holiday accommodation in a property known as Flagstaff House, Burnham Overy Staithe, King’s Lynn, Norfolk (the property). Mrs Green had bought the property for £900,000 in 2003. Between 2009-2012, the property was let for a total of around 650 to 750 nights a year. At all relevant times, Mrs Green lived in Woodbridge, Suffolk. On 2 February 2010, the property was valued by a firm of estate agents at £1.9m on a vacant possession basis.
On 5 April 2010, Mrs Green settled ...