Viscount Hood, Executor of the Estate of Lady Diana Hood v The Commissioners for HM Revenue and Customs: [2017] UKUT 0276 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Rose and Judge Bishopp on 7 July 2017.
Read the full decision in .
INHERITANCE TAX 鈥� deceased granted reversionary sub-lease to sons out of her head leasehold interest 鈥� licence to sub-let given by head landlord to deceased 鈥� sub-lease provided for same covenants, including repairing covenants, as in head lease 鈥� whether property disposed of by way of gift was subject to a reservation under s 102 FA 1986 鈥� application of second limb of s 102(1)(b) 鈥� identification of donated property 鈥� whether benefit 鈥榯renched upon鈥� donees鈥� enjoyment of the donated property - Buzzoni considered.
Updates to this page
Published 7 July 2017