Executors of the estate of Linington & anr v Commissioners for HMRC [2023] WTLR 917

Wills & Trusts Law Reports | Autumn 2023 #192

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...

Wagstaff & anr v HMRC [2014] UKFTT 43 (TC)

Wills & Trusts Law Reports | April 2014 #138

During 1990 Mr Wagstaff’s mother (Barbara) bought a flat for herself to live in (the flat). On 6 January 1996 she sold the flat to the appellants for £45,000. It was agreed that this was an arm’s length price. The sale was subject to the terms of an agreement of the same date (the agreement). The agreement provided that Barbara was entitled to continue to live at the flat at no cost until her death or remarriage, subject to a payment of £5,000.

Barbara continued to occupy the property until August 2005 when an accident meant she could no longer do so. After some time ...