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Introduction

Basis of valuation: Summary

Basis of valuation: Burden of tax

Basis of valuation: Treatment of expenses

Specific lifetime exemptions: Summary

Specific lifetime exemptions: Order in which exemptions apply

Annual exemption: Summary

Annual exemption: Relievable property

Annual exemption: Multiple transfers

Annual exemption: Roll over provisions

Schemes to exploit annual exemption: Introduction

Schemes to exploit annual exemption: Transfer by sale

Schemes to exploit annual exemption: Transfer of part of a property

Schemes to exploit annual exemption: Transfer of sum of money

Schemes to exploit annual exemption: Transfer of share equal to a sum of money

Schemes to exploit annual exemption: Transfer of shares quantified by loss in value

Schemes to exploit annual exemption: Split proceeds from property on trust for sale

Small gifts exemption: Summary

Gifts in consideration of marriage or registration of civil partnership: Summary

Gifts in consideration of marriage or registration of civil partnership: Permissible beneficiaries for s.22 purposes

Gifts in consideration of marriage or registration of civil partnership: Rennell v IRC

Gifts in consideration of marriage or registration of civil partnership: Rennell v IRC - gifts by way of settlement

Gifts in consideration of marriage or registration of civil partnership: IHTA restrictions of Rennell - outright gifts and other dispositions

Gifts in consideration of marriage or registration of civil partnership: IHTA restrictions of Rennell - the eventual recipient

Gifts in consideration of marriage or registration of civil partnership: IHTA restrictions of Rennell - IHTA84/S22 (4)(b) provisions

Gifts in consideration of marriage or registration of civil partnership: IHTA restrictions of Rennell - payments under covenant

Gifts in consideration of marriage or registration of civil partnership: Relationship with spouse or civil partner exemptions

Gifts in consideration of marriage or registration of civil partnership: Termination of IIP in settled property

Normal expenditure out of income: Introduction

Normal expenditure out of income: Life policy linked with an annuity

Normal expenditure out of income: Loans

Conditions for normal out of income exemption: Normal expenditure

Conditions for normal out of income exemption: Pattern of gifts

Conditions for normal out of income exemption: Factors to consider

Conditions for normal out of income exemption: Case Law - Bennett v IRC

Conditions for normal out of income exemption: Out of income

Conditions for normal out of income exemption: Case Law - McDowall

Conditions for normal out of income exemption: Transferor's standard of living

Gifts with reservation (GWRs): Requirements for a GWR

Gifts with reservation (GWRs): Devolution of GWR property

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp gift: Initial requirements

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp gift: »Ê¹ÚÌåÓýapp donor

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp gift: »Ê¹ÚÌåÓýapp property given

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp gift: Examples of the property given - carve-out arrangements

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp gift: Defining the gift

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp gift: Sales for less than full consideration

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp gift: Interest free loans

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp gift: Exempt transfers which cannot be GWRs

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp gift: Exempt transfers which can be GWRs

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Initial requirements

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Possession and enjoyment by the donee

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Exclusion of the donor

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Examples of exclusion of the donor

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Non-exclusion need not be continuous

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Effect of consideration

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Continuation of reasonable commercial arrangements

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Benefit by associated operations

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Benefit to donor's spouse or civil partner

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: When occupation is not a reservation

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Full consideration in cases of land and chattels

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Infirm relative

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Annual exemption

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation: Interests in land

Gifts with reservation (GWRs): Tracing: Introduction

Gifts with reservation (GWRs): Tracing: Absolute gifts of cash

Gifts with reservation (GWRs): Tracing: Absolute gifts of property other than cash

Gifts with reservation (GWRs): Tracing: Supplementary provisions

Gifts with reservation (GWRs): Settled property: Introduction

Gifts with reservation (GWRs): Settled property: »Ê¹ÚÌåÓýapp donee and the property given

Gifts with reservation (GWRs): Settled property: Settlement on discretionary trusts

Gifts with reservation (GWRs): Settled property: Donor also a trustee

Gifts with reservation (GWRs): Settled property: Reasonable commercial arrangements

Gifts with reservation (GWRs): Settled property: Settlement created when the settlor is domiciled outside the UK

Gifts with reservation (GWRs): Tracing settled property: »Ê¹ÚÌåÓýapp property comprised in the gift

Gifts with reservation (GWRs): Tracing settled property: If the property ceases to be settled

Gifts with reservation (GWRs): Tracing settled property: Settlement by the donee

Gifts with reservation (GWRs): Insurance policies: Introduction

Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: General gifts after 18 March 1986

Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: Normal out of income exemption on regular premiums

Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: Policies made before 18 March 1986

Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: Automatic increases in policy value

Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: Change in life assured

Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: »Ê¹ÚÌåÓýapp property given

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation on insurance policies: Introduction

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation on insurance policies: Special rule for policies with linked benefits

Gifts with reservation (GWRs): »Ê¹ÚÌåÓýapp reservation on insurance policies: Reservation examples

»Ê¹ÚÌåÓýapp charge to tax: Cumulation

»Ê¹ÚÌåÓýapp charge to tax: Cumulation with the death estate

»Ê¹ÚÌåÓýapp charge to tax: Potentially exempt transfers (PETs): Tax treatment of a PET

»Ê¹ÚÌåÓýapp charge to tax: Potentially exempt transfers (PETs): Tax treatment of a PET followed by death

»Ê¹ÚÌåÓýapp charge to tax: Potentially exempt transfers (PETs): Cumulation

»Ê¹ÚÌåÓýapp charge to tax: Potentially exempt transfers (PETs): Cumulating transfers more than seven years before death

»Ê¹ÚÌåÓýapp charge to tax: Potentially exempt transfers (PETs): IHT nil rate band

»Ê¹ÚÌåÓýapp charge to tax: Potentially exempt transfers (PETs): Rate of tax

»Ê¹ÚÌåÓýapp charge to tax: Potentially exempt transfers (PETs): Taper relief

»Ê¹ÚÌåÓýapp charge to tax: Potentially exempt transfers (PETs): Fall in value relief

»Ê¹ÚÌåÓýapp charge to tax: Potentially exempt transfers (PETs): Special rate

»Ê¹ÚÌåÓýapp charge to tax: Immediately chargeable transfers: Introduction

»Ê¹ÚÌåÓýapp charge to tax: Immediately chargeable transfers: Value for tax

»Ê¹ÚÌåÓýapp charge to tax: Immediately chargeable transfers: Cumulation

»Ê¹ÚÌåÓýapp charge to tax: Immediately chargeable transfers: Rate of tax

»Ê¹ÚÌåÓýapp charge to tax: Grossing: When to gross-up

»Ê¹ÚÌåÓýapp charge to tax: Grossing: When not to gross-up

»Ê¹ÚÌåÓýapp charge to tax: Grossing: Partial grossing

»Ê¹ÚÌåÓýapp charge to tax: Grossing: »Ê¹ÚÌåÓýapp grossing calculation

»Ê¹ÚÌåÓýapp charge to tax: Grossing: Tax paid after death of the transferor

»Ê¹ÚÌåÓýapp charge to tax: Grossing: Settled property

»Ê¹ÚÌåÓýapp charge to tax: Grossing: Authority for grossing

»Ê¹ÚÌåÓýapp charge to tax: Other charges: Late reported transfers

»Ê¹ÚÌåÓýapp charge to tax: Other charges: Death subsequent to the transfer

»Ê¹ÚÌåÓýapp charge to tax: Additional charges: Introduction

»Ê¹ÚÌåÓýapp charge to tax: Additional charges: Value for tax

»Ê¹ÚÌåÓýapp charge to tax: Additional charges: Cumulation

»Ê¹ÚÌåÓýapp charge to tax: Additional charges: Rate of tax

»Ê¹ÚÌåÓýapp charge to tax: Additional charges: Taper relief

»Ê¹ÚÌåÓýapp charge to tax: Additional charges: »Ê¹ÚÌåÓýapp additional tax payable

»Ê¹ÚÌåÓýapp charge to tax: Additional charges: »Ê¹ÚÌåÓýapp additional tax payable (example 1)

»Ê¹ÚÌåÓýapp charge to tax: Additional charges: »Ê¹ÚÌåÓýapp additional tax payable (example 2)

»Ê¹ÚÌåÓýapp charge to tax: Reliefs: Business relief and agricultural relief

»Ê¹ÚÌåÓýapp charge to tax: Reliefs: Fall in value relief

»Ê¹ÚÌåÓýapp charge to tax: »Ê¹ÚÌåÓýapp charge on lifetime transfers: Gifts with reservation (GWRs)

»Ê¹ÚÌåÓýapp charge to tax: »Ê¹ÚÌåÓýapp charge on lifetime transfers: Simultaneous and same day transfers

»Ê¹ÚÌåÓýapp charge to tax: »Ê¹ÚÌåÓýapp charge on lifetime transfers: Liability for payment of tax

»Ê¹ÚÌåÓýapp charge to tax: »Ê¹ÚÌåÓýapp charge on lifetime transfers: Grossing-up the values

»Ê¹ÚÌåÓýapp charge to tax: »Ê¹ÚÌåÓýapp charge on lifetime transfers: Late reported transfers

Specific lifetime reliefs: Taper relief: When the relief applies

Specific lifetime reliefs: Taper relief: Quantifying the relief

Specific lifetime reliefs: Taper relief: Period of survival

Specific lifetime reliefs: Fall in value relief: Introduction

Specific lifetime reliefs: Fall in value relief: Form of the relief

Specific lifetime reliefs: Fall in value relief: Conditions for relief

Specific lifetime reliefs: Fall in value relief: What is a qualifying sale?

Specific lifetime reliefs: Fall in value relief: What is market value?

Specific lifetime reliefs: Fall in value relief: »Ê¹ÚÌåÓýapp claim

Specific lifetime reliefs: Fall in value relief: Wasting assets

Specific lifetime reliefs: Fall in value relief: Portfolio of assets

Specific lifetime reliefs: Fall in value relief: More than one sale

Specific lifetime reliefs: Fall in value relief: Not all of the transferred assets are sold

Specific lifetime reliefs: Shares and securities: Adjustments

Specific lifetime reliefs: Shares and securities: Capital receipts

Specific lifetime reliefs: Shares and securities: Payment of calls

Specific lifetime reliefs: Shares and securities: Changes in shareholdings

Specific lifetime reliefs: Shares and securities: Transactions of close companies

Specific lifetime reliefs: Interests in land: Changes between transfer and death

Specific lifetime reliefs: Interests in land: Changes that have reduced the value

Specific lifetime reliefs: Interests in land: Changes that have increased the value

Specific lifetime reliefs: Interests in land: Compensation

Specific lifetime reliefs: Interests in land: Leases

Specific lifetime reliefs: Interests in land: Other property

Double charges relief: When double charges arise

Double charges relief: Applying the relief

Double charges relief: Authority for the relief

Double charges relief: Potentially exempt transfers (PETs): When double charges relief arises

Double charges relief: Potentially exempt transfers (PETs): Partial consideration

Double charges relief: Potentially exempt transfers (PETs): Property representing the property transferred

Double charges relief: Potentially exempt transfers (PETs): Calculations

Double charges relief: Potentially exempt transfers (PETs): Quick succession relief (QSR)

Double charges relief: Gifts with reservation (GWRs): When double charges relief arises

Double charges relief: Gifts with reservation (GWRs): Calculations

Double charges relief: Gifts with reservation (GWRs): Example of calculations 1

Double charges relief: Gifts with reservation (GWRs): Example of calculations 2

Double charges relief: Disallowed debts: When double charges relief arises

Double charges relief: Disallowed debts: Calculations

Double charges relief: Disallowed debts: Transfers chargeable when made

Double charges relief: Disallowed debts: Calculations producing the same amount

Double charges relief: Disallowed debts: Discretionary trusts

Omissions: Possible omissions of lifetime transfers

Omissions: Omission to exercise a right

Associated operations: Why are the provisions necessary?

Associated operations: Definition

Associated operations: »Ê¹ÚÌåÓýapp objective test

Associated operations: »Ê¹ÚÌåÓýapp subjective test

Associated operations: Additional provisions

Associated operations: Definition of terms

Associated operations: Transfer of value made by associated operations

Associated operations: Restrictions on association

Associated operations: Re Macpherson

Associated operations: Insurance policies

Associated operations: Gifts With Reservation

Associated operations: Transfers involving relievable property

Associated operations: Gifts between spouses or civil partners

Associated operations: Sale without immediate payment of the purchase price

Associated operations: Transfer in stages

Associated operations: Successive settlements

Transfers by close companies: Introduction

Transfers by close companies: Transfers of value

Transfers by close companies: Exemptions

Transfers by close companies: Foreign aspects

Transfers by close companies: Alterations in share capital, loan capital or rights

Transfers by close companies: Liability to tax

Future payments: Introduction

Future payments: Calculating the chargeable portion

Future payments: Exemptions

Future payments: Payments outstanding at death

Dating of dispositions: Introduction

Dating of dispositions: Gifts by cheque

Dating of dispositions: Dispositions affecting land

Dating of dispositions: Chattels and corporeal moveables

Dating of dispositions: Choses in action and incorporeal moveables

Investigation issues: Voidable transfers

Investigation issues: Donatio Mortis Causa (DMC)