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Peter Routier and Christine Venables (as executors of the late Beryl Coulter) v CRC, Court of Appeal, 16 September 2016
Interpretation of IHTA 1984 s 23
In her will Beryl Coulter had left her residuary estate on trust for the purpose of building homes for elderly residents of the parish of St Ouen in Jersey or in default to assist with the capital expenditure required by an organisation called Jersey Hospice Care.
The trust was established under and subject to Jersey law and as such was not a charity under ITA 2007 s 989. It also followed that the will had not effected a transfer to ‘a trust established for charitable purposes only’ because IHTA 1984 s 23 required it to be established in the UK.
HMRC said the executors were therefore liable for inheritance tax of £600 000. The matter proceeded to the High Court which found for HMRC.
The executors appealed.
The appeal raised two issues. The first was whether the residuary estate...
