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09 August 2007
Issue: 7285 / Categories: Features , Wills & Probate
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Wills and Probate

FROM THE REVENUE

The PRs of Harry Dexter Lyon deceased and the Trustees of the Alloro Trust v HMRC Spc 616, 21 May 2007

The trustees of the Alloro Trust (the trust) appealed against HM Revenue & Customs’ (HMRC’s) notice of determination that the property held at the date of death by the trust should be treated as property to which Mr L was beneficially entitled. The amount of tax in dispute was about £200,000. The relevant legislation was the Inheritance Tax Act 1984, ss 4 and 5 and the Finance Act 1986 (FA 1986), s 102.

Mr L gifted £2.7m to the trust, of which he was in the class of potential beneficiaries and received distributions totalling £15,965 during his lifetime.
The issue was whether or not the fact that Mr L was in the class of discretionary beneficiaries meant there was a reservation of benefit within the meaning of FA 1986, s 102(1).

The special commissioner made the following findings of fact:
- Mr L was one of the beneficiaries of the trust set up by

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MOVERS & SHAKERS

NLJ Career Profile: Stephen Ward, The Barrister Group

NLJ Career Profile: Stephen Ward, The Barrister Group

From mowing lawns to life at the Bar: Stephen Ward reflects on an unconventional career

Clarke Willmott—Ben Loosemore

Clarke Willmott—Ben Loosemore

Commercial property partner joins Clarke Willmott in Southampton

Ellisons—Robert Tiffen

Ellisons—Robert Tiffen

Robert Tiffen joins Ellisons as Partner in growing Norwich office

NEWS
The Law Society RFC Festival of Sport returns next month, bringing together legal and financial services professionals for one of the sector’s largest annual sporting events
Legal aid deserts leave almost one in four without adequate access to justice
The Solicitors Regulation Authority (SRA) has warned solicitors and law firms that using artificial intelligence does not alter their professional obligations, amid concerns over inaccurate legal material and client confidentiality
From forgotten interest claims to case-management appeals, a string of procedural developments offers useful—and occasionally cautionary—lessons for practitioners

Jonathan Fisher KC highlights that it now accounts for around 40% of criminal offences, with roughly 70% involving technology, and argues that the UK cannot simply prosecute its way out of the problem. Detection, investigation and prosecution all require improvement, while different fraud types demand tailored responses.

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