Shelford & anr v HMRC [2020] WTLR 657

Wills & Trusts Law Reports | Summer 2020 #179

John Selwyn Herbert (Mr Herbert), a widower with three children, owned and lived in the freehold house, 12 Hammersmith Terrace, London (the house). In 2001, Mr Herbert obtained inheritance tax advice from Stevens & Bolton to implement what was described as the ‘home loan scheme’ and he asked the second appellant, Mr Shelford, who was a solicitor and partner in Edwin Coe, to act as a trustee of the Herbert Life Interest Settlement (the settlement).

The settlement, which was dated 21 March 2002, was established by Mr Herbert with a nominal sum of £10 upon trust for himself durin...