A reversionary interest was not excluded property because consideration was given for its acquisition, but there was no loss to the value of the taxpayer’s estate immediately following the transfer of that interest.
The deceased (Mr S), who was domiciled in the UK, entered into IHT planning arrangements in 2009 (prior to legislation designed to block similar planning arrangements (IHTA 1984, s 74A)), before his death. The arrangements involved the transfer of a reversionary interest in an Isle of Man (IoM) trust to a family trust (DSFT).
The IoM trust (BT) was settled by an IoM company (B) in 2008. The beneficiaries of BT were an income beneficiary (B) and reversionary beneficiary (another IoM company (G)). In April 2008, B borrowed £1 million from a bank and transferred it to BT. In June 2009, Mr S was nominated as the trust’s reversionary beneficiary in place of G. Subsequently, Mr S agreed to acquire
