The reservation of benefit legislation continues to be relevant to IHT planning, and the 2017 changes to foreign domiciliaries have extended its scope and importance. Emma Chamberlain (Pump Court Tax Chambers) provides a practical guide to navigating the rules.
IHT cases can be a little like buses: there are none at all for some years and then two come along in swift succession. Two important cases clarifying the scope of the reservation of benefit (ROB) provisions were recently heard by the Court of Appeal: Buzzoni and others v HMRC ; In re the Estate of Kamhi decd (Buzzoni) [2013] EWCA Civ 1684 and Viscount Hood (Executor of the Estate of Lady Diana Hood) v HMRC (Lady Hood) [2018] EWCA Civ 2405. Both consider the ROB legislation although the Court of Appeal reached different conclusions in each case. The case law generally illustrates the difficulty of applying the ROB provisions...
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The reservation of benefit legislation continues to be relevant to IHT planning, and the 2017 changes to foreign domiciliaries have extended its scope and importance. Emma Chamberlain (Pump Court Tax Chambers) provides a practical guide to navigating the rules.
IHT cases can be a little like buses: there are none at all for some years and then two come along in swift succession. Two important cases clarifying the scope of the reservation of benefit (ROB) provisions were recently heard by the Court of Appeal: Buzzoni and others v HMRC ; In re the Estate of Kamhi decd (Buzzoni) [2013] EWCA Civ 1684 and Viscount Hood (Executor of the Estate of Lady Diana Hood) v HMRC (Lady Hood) [2018] EWCA Civ 2405. Both consider the ROB legislation although the Court of Appeal reached different conclusions in each case. The case law generally illustrates the difficulty of applying the ROB provisions...
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