Charles Cooper | Barrister & Mediator

Category: Tax

Elborne & Ors v. HMRC [2026] EWCA Civ 894

A version of the so-called home loan scheme, involving sale of Mrs E’s home to a trust for her benefit in exchange for a promissory note, then assignment of the note by way of gift to the trustees of a second trust for her children’s benefit, allowed her to remain living in the home rent-free…
Read more: Elborne & Ors v. HMRC [2026] EWCA Civ 894
Wood v. HMRC [2026] UKFTT 589 (TC)

Considering the decision in HMRC v. Parry [2020] UKSC 35, while the subjective intentions of the donor are relevant to determining whether s.10(1) Inheritance Tax Act 1984 (dispositions not intended to confer gratuitous benefit) applies, donations to further a political objective are still transfers of value and subject to Inheritance Tax – a donor ‘…cannot…
Read more: Wood v. HMRC [2026] UKFTT 589 (TC)
Lexgreen Services Ltd v. HMRC [2025] UKFTT 1019 (TC)

A company that has made contributions to a trust can be liable for any Inheritance Tax arising on the 10 year anniversary of that trust by virtue of s.201(1)(d) IHTA 1984 ‘if that company is a live company at the time of the relevant transfer’: https://caselaw.nationalarchives.gov.uk/ukftt/tc/2025/1019
Read more: Lexgreen Services Ltd v. HMRC [2025] UKFTT 1019 (TC)