Sussman v HMRC [2016] UKFTT 523 (TC)

Wills & Trusts Law Reports | October 2016 #163

The appellant was the personal representative and trustee of the estate of Mrs Sussman (the deceased) who died in 2006. The appeal concerned whether a residential property (the property) was part of the deceased’s estate, and the treatment of the property for IHT purposes. The appeal also concerned appeals out of time, as the appellant’s application to bring an appeal out of time was heard as a preliminary matter immediately before the substantive appeal.

The property had belonged to the deceased’s late husband. The deceased received an interest in possession in ...

Hood [2016] UKFTT 059 (TC)

Wills & Trusts Law Reports | June 2016 #160

Lady Hood was the lessee of the property in Chelsea (‘the property’) pursuant to a lease (‘the head lease’) dated 21 September 1979 and made between (1) Viscount Chelsea (‘the head lessor’) (2) the Chelsea Land & Investment Company Limited (‘Chelsea land”); (3) Cadogan Holdings Company (‘Cadogan’) and (4) Lady Hood. The head lease contained a covenant by the lessee not to transfer underlet or part with possession of part of the demised premises without consent of Cadogan. The head lease also contained a right for the head lessor or the Company to forfeit the head lease for breaches o...

Gifts With Reservation: A win for the taxpayer

Mary Ashley gives an update on the long-running case of Buzzoni v HMRC ‘Buzzoni provided a rare opportunity for the Court of Appeal to clarify how the gifts with reservation rules apply.’ The reservation of benefit rules in relation to inheritance tax (IHT) have always been a hiccup in the planning context. This has led …
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