A property in which the deceased had an interest in possession formed part of her estate on death for IHT purposes, notwithstanding an earlier deed which purported to remove the property from the deceased’s estate.
The deceased died in 2006. The appellant (the deceased’s personal representative) submitted an inheritance tax (IHT) account (IHT200) to HM Revenue and Customs (HMRC) in February 2007. One of the assets shown on the account was a residential property. IHT was payable in respect of the property.
In June 2014, the appellant submitted a new IHT200, which was prepared on the basis that the residential property did not form part of the deceased’s estate. The appellant claimed that the effect of a deed of trust entered into by the deceased in May 1998 (which named the appellant as the beneficiary) was to remove the property from the deceased’s estate for IHT purposes (or, possibly, to reduce its
