Firth & anr v Commissioners for HMRC [2022] WTLR 1297
Wills & Trusts Law Reports | Winter 2022 #189The appeal was brought by Mr and Mrs Firth in their capacity as trustees of the L. Batley 1984 Settlement (the trust) against notices of determination issued to the trustees by HMRC on 7 September 2018, which refused Inheritance Tax (IHT) Business Property Relief (BPR) on the grounds that the interest of the trustees in the business carried on by the Lawrance (Hotel Living) Ltd (The Lawrance) consisted mainly in the holding of investments and was therefore not a qualifying business for the purposes of BPR.
On 14 November 1984 Lawrance Batley established the trust. Prior to 2012 th...
Executors of the estate of Ross v HMRC [2018] WTLR 1417
Wills & Trusts Law Reports | Winter 2018 #170Mrs Ross originally owned a hotel called the Port Gaverne Inn in Cornwall and later acquired eight holiday cottages across the road called the Green Door Cottages. When she was no longer fit enough to run the business, the hotel was sold though its new owner agreed to provide services to guests renting out the cottages. A handyman was employed by the partnership which owned the cottages and other properties. When Mrs Ross died on 7 November 2011, she was entitled to a two-thirds share in the partnership and the total value of all the properties held by it amounted to £1.5m. The appellant...