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J Matthews v HMRC

IHT: beneficial ownership

In J Matthews v HMRC (TC02329 – 7 November) an elderly widow who had inherited some money from her father transferred £94 000 from a bank account in her name to a new account in the joint names of her and her son (M). She died eight years later. HMRC issued a notice of determination charging IHT on the whole amount held in the account. The FTT upheld the determination and dismissed M’s appeal applying the principles laid down in Sillars & Another v CIR Sp C [2004] STC (SCD) 180. 

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Why it matters: The FTT upheld HMRC’s contention that IHT was chargeable on the whole of the amount held in the relevant bank account at the time of the...

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