Salinger & anr v HMRC [2016] UKFTT 677 (TC)
Wills & Trusts Law Reports | 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...