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Is relief from a double IHT charge available under the Inheritance Tax (Double Charges Relief) Regulations 1987 SI 1987/1130 where an individual (D) transfers an asset to a trust under which D can benefit the trustees appoint the asset back to D and D dies within seven years of both the initial transfer and the appointment?
Query 20 131 – Arboreum.
Some element of double taxation will apply.
The Inheritance Tax (Double Charges Relief) Regulations SI 1987/1130 provide relief from double taxation in various circumstances. The main provisions of the regulations contained in regs 4 to 7 reference the four sub-provisions of FA 1986 s 104(1).
Although we are not expressly told we assume the trust to which the assets were transferred was a relevant property settlement and this gave rise to both an entry charge under IHTA 1984 s 3 and...
