Hood (executor of the estate of Hood) v Revenue and Customs Commissioners

Inheritance tax – Lifetime transfer. The deceased had granted a reversionary sub-lease to her sons out of her head leasehold interest which had contained certain covenants, mirroring those in the head-lease. The Upper Tribunal (Tax and Chancery Chamber) upheld the decision of the First-tier Tribunal (Tax Chamber) that the estate was liable for inheritance tax on the value of the sons' sub-lease because, due to the reservation in the sub-lease, under s 102 of the Inheritance Act 1984, as property subject to a reservation, it fell to be treated as property to which she had become beneficially entitled immediately before her death and therefore formed part of her estate on her death.

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