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J Shelford, I Lazar, R Herbert and M Herbert (as executors of J Herbert deceased) and J Shelford (as trustee of the Herbert Life Interest Trust Settlement) (TC7549)
In 2002, Mr H (who died in 2013) entered into a home loan scheme. The agreed purpose was to remove the value of his home from his estate for inheritance tax purposes while he continued to live in it rent-free until his death.
Broadly, this involved the sale of Mr H’s home to a trust in return for a loan which was gifted to his children. The agreements were intended to provide stamp duty savings, in essence, by deferring completion after exchange. With effect from 6 April 2005, Mr
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