Tax planning disaster averted

Our clients’ mother had entered into a tax planning arrangement involving her house, following advice from her accountant.   She had given the house to her children, but continued to live there under a lease (an “Ingram” scheme).  However, steps were not taken to preserve the benefit of the scheme when the lease expired.  Following the mother’s death, HMRC argued that inheritance tax was due on the house under the “reservation of benefit” rules.  Mark Politz was instructed to advise on this matter and, with the assistance of a barrister, he argued strongly that the particular circumstances of this case were covered by one of the exceptions contained in the reservation of benefit rules.  HMRC accepted our arguments and the supporting evidence, with the result that no inheritance tax was due.