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IHT planning...what have you done?

Practical Issues
scrumpyjack
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Re: IHT planning...what have you done?

#474788

Postby scrumpyjack » January 20th, 2022, 4:03 pm

https://www.peplows.co.uk/resources/fac ... ned-assets

Describes how POAT works and says that if Dad gives daughter cash and she then buys a house but dad moves into that house, POAT does not apply if there is more than 7 years between the gift of cash and the occupation.

Lootman
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Re: IHT planning...what have you done?

#474799

Postby Lootman » January 20th, 2022, 4:31 pm

genou wrote:What I find galling is that on all legal issues, your standard advice is "do what is convenient and as long as you don't get caught it'll be fine", which you appear to regard as a "practical" approach.

That was not what I was saying at all and it is offensive to suggest that I was proposing anything illegal.

What myself and others have been saying is that the POAT rules should not apply after the transaction is aged and the transfer becomes exempt rather than merely potentially exempt. And there are various very practical reasons why such a determination would never be made.

More generally it is perfectly possible for a question to have one answer in theory and another answer in practice. If I were asking the question here I would want to hear both sides of that.

Dod101 wrote:
genou wrote:
MyNameIsUrl wrote:... if the agreement is 'I will give you a house without any strings attached whatsoever' then it seems to me after 7 years have elapsed the gift is free from IHT, even if I move into it after 3 years, because that moving in becomes a new separate arrangement and I never 'reserved' the benefit for myself. So, providing an agreement is made and documented when a cash gift or any other gift is made that there is no reservation of benefit, that's the end of it and after 7 years I can shred all the documentation and no IHT can ever be due on that gift.

I think you may well be right on IHT, but at the point you move back in to the house, I reckon you get clattered by the POAT rules, at which point you may want to elect for it to be a GWROB if you can, as it could easily be less tax.

Everyone is getting a bit rattled but personally I doubt very much that the POAT rules apply in this sort of case. The gift is well passed the 7 year period and therefore that transaction is dead and buried. If the owner of the house then offers Mum accommodation at a much later date that is out of the goodness of his/her heart and he/she can do so or not; there has been no reservation of benefit or attempt to use a 'scheme' to avoid IHT. I simply do not believe the POAT rules apply.

I would be a bit nervous about Lootman's case of moving in after three years, notwithstanding that there has been no formal reservation of benefit. If HMRC got to know about (and why would they?) they might well have some probing questions although logically as Lootman says they are two separate and distinct transactions. It is how to prove it that matters.

Agreed and I don't know why genou got rattled merely by pointing out some fairly obvious features of a situation like this. As you say it all goes back to the intent at the time of the original transfer. And after 7 years it all becomes moot anyway.

But if anyone has any residual doubts about it and is the worrying type, then selling an asset and then transferring the cash instead seems foolproof.

As for proving that a gift was made unconditionally the simplest thing might simply be a document prepared at the time of the transfer, recording the fact that it is a true gift with no consideration or reservation. Hard to see how anyone could prove otherwise in that case.

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Re: IHT planning...what have you done?

#474809

Postby MyNameIsUrl » January 20th, 2022, 5:12 pm

Lootman wrote:...As for proving that a gift was made unconditionally the simplest thing might simply be a document prepared at the time of the transfer, recording the fact that it is a true gift with no consideration or reservation. Hard to see how anyone could prove otherwise in that case.


I agree. When I made a cash gift to my son to help him to buy a house, his solicitor asked me to confirm in writing a few AML questions and the wording 'I confirm the amount being gifted is £x, which is not repayable under any circumstances. I confirm that I am not obtaining any interest in the new property'. As far as I can see that arrangement cannot be retrospectively changed by any future action. After 7 years any IHT liabilities have disappeared even if I do move into his house.

(Clearly if there was suspicion the arrangement was a sham it could be challenged as never valid, but I think the involvement of a solicitor in the process would give it some credence.)

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Re: IHT planning...what have you done?

#474845

Postby Eboli » January 20th, 2022, 7:58 pm

MyNameIsUri observed:

If I'd made the gift on 1 Jan 1999 I would have expected to shred the records of that gift on 1 Jan 2006, having survived 7 years.


Sorry, you would be wrong to do so. At that time the gift would still only be POTENTIALLY exempt.

And:

If I'd made the gift of a house, I presume the reservation of benefit would be my living in it 20 years later, but if the gift was cash, it's hard to see how a reservation of benefit could arise many years later (even if the cash had been used by the recipient to buy a house).


I would suggest looking at the pre-owned asset rules that start here:

https://www.gov.uk/hmrc-internal-manual ... /ihtm44001

It is clear under the 'contribution rule' that the circumstances you describe would catch you. So you either accept a reservation of benefit under IHT or an income tax charge under the pre-owned asset rules.

Eb.

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Re: IHT planning...what have you done?

#474847

Postby Eboli » January 20th, 2022, 8:14 pm

Lootman observed:

Surely you can only "reserve a benefit" at the point of making a gift, or within 7 years of making that gift.

So if A makes a gift to B in 1999 then it becomes exempt in 2006, and nothing that happens after that matters. At that point A could indeed benefit from the gift without any effect.


I would suggest that Finance Act 1986 s 102 (1) - the relevant section for gifts with reservations, says differently. It says:

Gifts with reservation

(1)Subject to subsections (5) and (6) below, this section applies where, on or after 28th March 1986, an individual disposes of any property by way of gift and either—

(a)possession and enjoyment of the property is not bona fide assumed by the donee at or before the beginning of the relevant period; or

(b)at any time in the relevant period the property is not enjoyed to the entire exclusion, or virtually to the entire exclusion, of the donor and of any benefit to him by contract or otherwise;

and in this section “the relevant period” means a period ending on the date of the donor’s death and beginning seven years before that date or, if it is later, on the date of the gift.


Note that the 'relevant period' is back from the date of death.

Eb

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Re: IHT planning...what have you done?

#474849

Postby Eboli » January 20th, 2022, 8:22 pm

Lootman also observed:

In general I would agree although I can think of a couple of examples where the taxman might win the debate:

1) A gives B a sum of £100,000 and tells B that if at some later time A is short of money then he would like the money to be re-gifted back to him. The taxman would take the view that that was really a loan, even if no interest is paid, because the right to get the money back reserved a benefit i.e. the potential future use of those funds.

2) A gives B a sum of £100,000 so that B can buy a house to live in. At some later time B lets A live in that house. I think you and I take the view that if A only moves into B's house after 7 years then it is not a problem. But Eboli seems to think that it might be.


Example 1 is just misplaced. You cannot reserve a benefit over cash. Instead the tracing provisions apply.

Example 2 is a clear breach of the pre-owned assets rules and would give rise to an income tax charge under Finance Act 2004 Sch 15. in particular the contribution condition of para 3(3) would clearly apply as this states:

(3)The contribution condition is that at any time after 17th March 1986 the chargeable person has directly or indirectly provided, otherwise than by an excluded transaction, any of the consideration given by another person for the acquisition of—

(a)an interest in the relevant land, or

(b)an interest in any other property the proceeds of the disposal of which were (directly or indirectly) applied by another person towards the acquisition of an interest in the relevant land.


And for the avoidance of doubt the scope of the charge is provided by para 3(1):

3(1)This paragraph applies where—

(a)an individual (“the chargeable person”) occupies any land (“the relevant land”), whether alone or together with other persons, and

(b)the disposal condition or the contribution condition is met as respects the land.


Eb.

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Re: IHT planning...what have you done?

#474852

Postby Eboli » January 20th, 2022, 8:27 pm

Scrumpyjack observed:

If the gift was made unconditionally with no commitments to what might happen in the future and no benefit was received in the 7 years, I can't see how anyone could argue that there had been a reservation of benefit.


This is simply wrong. Counting forward from the date of gift, if in year 7+x (a year prior to 7+y when the donor dies) a reservation of benefit occurs (even if none occurred in the first 7 years) and 7+x is within 7 years of 7+y there is a reservation of benefit unless full consideration is provided. See my quotation of FA 1986 s 102 above. This is a very common mistake, I used to see it on a daily basis.

A further observation:

[the guide] Describes how POAT works and says that if Dad gives daughter cash and she then buys a house but dad moves into that house, POAT does not apply if there is more than 7 years between the gift of cash and the occupation.


That is simply wrong. The only time limit on POAT is the 1986 date - the date when CTT became IHT! This is made clear in HMRC's own instructions - which I would suggest ar better than the guide.

See:

https://www.gov.uk/hmrc-internal-manual ... /ihtm44005

Eb
Last edited by Eboli on January 20th, 2022, 8:38 pm, edited 1 time in total.

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Re: IHT planning...what have you done?

#474853

Postby Eboli » January 20th, 2022, 8:31 pm

genou observed:

I think you may well be right on IHT, but at the point you move back in to the house, I reckon you get clattered by the POAT rules, at which point you may want to elect for it to be a GWROB if you can, as it could easily be less tax.


Absolutely right! The only question would be whether the value of of POAT could be below the de minimis limits making it preferable to the GWROB.

Eb
Last edited by Eboli on January 20th, 2022, 8:42 pm, edited 1 time in total.

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Re: IHT planning...what have you done?

#474854

Postby Lootman » January 20th, 2022, 8:41 pm

Eboli wrote:MyNameIsUri observed:
If I'd made the gift on 1 Jan 1999 I would have expected to shred the records of that gift on 1 Jan 2006, having survived 7 years.

Sorry, you would be wrong to do so. At that time the gift would still only be POTENTIALLY exempt.

Hmm, well if no benefit had been reserved then MyName is correct. The 7-year clock has expired and the transfer is now exempt.

Whilst if a benefit was reserved then the 7-year clock hasn't even started ticking yet, and so it is still only potentially exempt.

This is all moot of course unless and until the donor dies. Only at that point does anyone ask the question about past gifts and their exemption. So it is typically the executor who makes this determination based on asking two questions: "What gifts have been made in the last 7 years" AND "what gifts were ever made where a benefit was reserved?"

Eboli wrote:
If I'd made the gift of a house, I presume the reservation of benefit would be my living in it 20 years later, but if the gift was cash, it's hard to see how a reservation of benefit could arise many years later (even if the cash had been used by the recipient to buy a house).

I would suggest looking at the pre-owned asset rules that start here:

https://www.gov.uk/hmrc-internal-manual ... /ihtm44001

It is clear under the 'contribution rule' that the circumstances you describe would catch you. So you either accept a reservation of benefit under IHT or an income tax charge under the pre-owned asset rules.

Just about nobody would choose the POAT option there. They would effectively choose the GWROB option (by doing nothing at the time and not reporting the gift) and defer the entire matter until the donor dies. Whereupon as noted above it is really up to the executor to decide how or whether to report the gift.

Cash gifts are notoriously difficult for anyone to discover and unravel, especially decades after they happened.

Eboli wrote:Scrumpyjack observed:
If the gift was made unconditionally with no commitments to what might happen in the future and no benefit was received in the 7 years, I can't see how anyone could argue that there had been a reservation of benefit.

This is simply wrong. Counting forward from the date of gift, if in year 7+x (a year prior to 7+y when the donor dies) a reservation of benefit occurs (even if none occurred in the first 7 years) and 7+x is within 7 years of 7+y there is a reservation of benefit unless full consideration is provided. See my quotation of FA 1986 s 102 above. This is a very common mistake, I used to see it on a daily basis.

May I ask in what capacity you saw this "on a daily basis"?

If you were looking at probate submissions then you most likely would never know what had been omitted.

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Re: IHT planning...what have you done?

#474858

Postby Eboli » January 20th, 2022, 8:53 pm

Lootman insists:

Hmm, well if no benefit had been reserved then MyName is correct. The 7-year clock has expired and the transfer is now exempt.

Whilst if a benefit was reserved then the 7-year clock hasn't even started ticking yet, and so it is still only potentially exempt.

This is all moot of course unless and until the donor dies. Only at that point does anyone ask the question about past gifts and their exemption. So it is typically the executor who makes this determination based on asking two questions: "What gifts have been made in the last 7 years" AND "what gifts were ever made where a benefit was reserved?"


No, no, no. The legislation is clear. Under FA 1986 s 102(4):

If, at a time before the end of the relevant period, any property ceases to be property subject to a reservation, the donor shall be treated for the purposes of the 1984 Act as having at that time made a disposition of the property by a disposition which is a potentially exempt transfer.
. So clearly it must be possible for the reservation to cease in the relevant period which (I have already supplied the quote) can be longer than 7 years! There is nothing moot about this. What you suggest is just wrong. Indeed you admit this with the second question which should be framed "what gifts have been made since 18th March 1986 in which a reservation of benefit has existed or continues to exist in the 7 years immediately before death.


Then you add:

Just about nobody would choose the POAT option there. They would effectively choose the GWROB option (by doing nothing at the time and not reporting the gift) and defer the entire matter until the donor dies. Whereupon as noted above it is really up to the executor to decide how or whether to report the gift.


There is no choice here if the POAT charge applies! But you now admit that there would be a reservation of benefit after the first 7 years! I am glad you are not my executor!

Seriously, this is very complex stuff and the reason why I originally posted is it is clear IHT just does not operate in the way you and others are suggesting (but your view is a common placed but misplaced view of the tax).

You also ask me in what capacity I saw this. I worked on CTT/IHT for over 40 years both as gamekeeper and poacher and wrote a legal guide to the tax within another work.

Eb

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Re: IHT planning...what have you done?

#474860

Postby Lootman » January 20th, 2022, 9:00 pm

Eboli wrote:Lootman insists:
Hmm, well if no benefit had been reserved then MyName is correct. The 7-year clock has expired and the transfer is now exempt.

Whilst if a benefit was reserved then the 7-year clock hasn't even started ticking yet, and so it is still only potentially exempt.

This is all moot of course unless and until the donor dies. Only at that point does anyone ask the question about past gifts and their exemption. So it is typically the executor who makes this determination based on asking two questions: "What gifts have been made in the last 7 years" AND "what gifts were ever made where a benefit was reserved?"

No, no, no. The legislation is clear. Under FA 1986(4):

If, at a time before the end of the relevant period, any property ceases to be property subject to a reservation, the donor shall be treated for the purposes of the 1984 Act as having at that time made a disposition of the property by a disposition which is a potentially exempt transfer.
. So clearly it must be possible for the reservation to cease in the relevant period which (I have already supplied the quote) can be longer than 7 years! There is nothing moot about this. What you suggest is just wrong. Indeed you admit this with the second question which should be framed "what gifts have been made since 18th March 1986 in which a reservation of benefit has existed or continues to exist in the 7 years immediately before death.

Then you add:

Just about nobody would choose the POAT option there. They would effectively choose the GWROB option (by doing nothing at the time and not reporting the gift) and defer the entire matter until the donor dies. Whereupon as noted above it is really up to the executor to decide how or whether to report the gift.

There is no choice here if the POAT charge applies! But you now admit that there would be a reservation of benefit after the first 7 years! I am glad you are not my executor!

Seriously, this is very complex stuff and the reason why I originally posted is it is clear IHT just does not operate in the way you and others are suggesting (but your view is a common placed but misplaced view of the tax).

The point of difference between you and genou on the one hand, and me, ScrumpyJack, MyName and Dod on the other, is quite simple.

You believe that if I gift a house with no intention of ever benefiting from it, but then decades later I do reside there, then GWROB applies. Whereas we are saying that it does not because there was no intention to do that. That is the nub of the two differing sets of views here.

I asked in what capacity you "see this every day" because I wish to understand where your different experience derives. As you appear to understand, this is not how executorship typically happens in the real world, even if you are correct that there may be some documentation somewhere that says that it should. So if we are all doing this wrong then HMRC are stunningly inept at discovering it.

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Re: IHT planning...what have you done?

#474864

Postby Eboli » January 20th, 2022, 9:15 pm

The point of difference between you and genou on the one hand, and me, ScrumpyJack, MyName and Dod on the other, is quite simple.

You believe that if I gift a house with no intention of ever benefiting from it, but then decades later I do reside there, then GWROB applies. Whereas we are saying that it does not because there was no intention to do that. That is the nub of the two differing sets of views here.

I asked in what capacity you "see this every day" because I wish to understand where your different experience derives. As you appear to understand, this is not how executorship typically happens in the real world, even if you are correct that there may be some documentation somewhere that says that it should. So if we are all doing this wrong then HMRC are stunningly inept at discovering it.


1. There is nothing in the definition of reservation of benefit in FA 1986 s 102 (1) that requires any intention on behalf of the donor. I repeat the definition here:

Gifts with reservation.

(1)Subject to subsections (5) and (6) below, this section applies where, on or after 28th March 1986, an individual disposes of any property by way of gift and either—

(a)possession and enjoyment of the property is not bona fide assumed by the donee at or before the beginning of the relevant period; or

(b)at any time in the relevant period the property is not enjoyed to the entire exclusion, or virtually to the entire exclusion, of the donor and of any benefit to him by contract or otherwise;

and in this section “the relevant period” means a period ending on the date of the donor’s death and beginning seven years before that date or, if it is later, on the date of the gift.


Exactly where is intention mentioned? I prefer to follow the law; you appear to be making the law up.

2. I cannot comment on the ineptitude or otherwise of HMRC as POAT was introduced after I had crossed over. Though I can tell you where to look in Hansard (Standing Committee F) FA 2004 in relation to Schedule 15 if you want, though it may take some time.

3. What you ought to accept is that IMHO most IHT submissions are wrong and most could be challenged. But then most would not pay the HMRC cost of the challenge primarily because there is not enough qualified manpower to employ on the problem. That gives an inaccurate reflection of the position.

Eb.

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Re: IHT planning...what have you done?

#474871

Postby Lootman » January 20th, 2022, 9:24 pm

Eboli wrote:What you ought to accept is that IMHO most IHT submissions are wrong and most could be challenged. But then most would not pay the HMRC cost of the challenge primarily because there is not enough qualified manpower to employ on the problem. That gives an inaccurate reflection of the position.

I do accept that. Although of course part of the "position" is that HMRC is very unlikely to challenge any submission anyway, for the reason you give. And people know that.

As a practical matter I keep a record of my gifts, and they drop off my spreadsheet after 7 years. So upon my demise my executor will no doubt rely upon my documentation and any gifts older than 7 years will not be noticed.

Then again my gifts are all cash and so GWROB, POAT and the rest are unlikely to apply anyway.

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Re: IHT planning...what have you done?

#474873

Postby Eboli » January 20th, 2022, 9:26 pm

For completeness, and I am sorry I had not mentioned this before, there ARE specific provisions where a benefit can be ignored over land and property but they are much narrower that not having the original intention. It is - note Lootman - specifically provided in what circumstances you can ignore the benefit under FA 1986 Sch 20 para 6, and they are very narrow indeed:

6(1)In determining whether any property which is disposed of by way of gift is enjoyed to the entire exclusion, or virtually to the entire exclusion, of the donor and of any benefit to him by contract or otherwise—

(a)in the case of property which is an interest in land or a chattel, retention or assumption by the donor of actual occupation of the land or actual enjoyment of an incorporeal right over the land, or actual possession of the chattel shall be disregarded if it is for full consideration in money or money’s worth;

(b)in the case of property which is an interest in land, any occupation by the donor of the whole or any part of the land shall be disregarded if—

(i)it results from a change in circumstances of the donor since the time of the gift, being a change which was unforseen at the time and was not brought about by the donor to receive the benefit of this provision; and

(ii)it occurs at a time when the donor has become unable to maintain himself through old age, infirmity or otherwise; and

(iii)it represents a reasonable provision by the donee for the care and maintenance of the donor; and

(iv)the donee is a relative of the donor or his spouse [F2or civil partner];

(c)a benefit which the donor obtained by virtue of any associated operations (as defined in section 268 of the 1984 Act) of which the disposal by way of gift is one shall be treated as a benefit to him by contract or otherwise.

(2)Any question whether any property comprised in a gift was at any time enjoyed to the entire exclusion, or virtually to the entire exclusion, of the donor and of the benefit to him shall (so far as that question depends upon the identity of the property) be determind by reference to the property which is at that time treated as property comprised in the gift.

(3)In the application of this paragraph to Scotland, references to a chattel shall be construed as references to a corporeal moveable.



Note that being unforeseen at the time of the gift is NOT sufficient as this is only part of 6(1)(b)(i), which in turn is only one of 4 conditions!

Eb

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Re: IHT planning...what have you done?

#474878

Postby scrumpyjack » January 20th, 2022, 9:46 pm

This appears to be the section of the HMRC Manual which specifies that if at least 7 years pass between the gift of cash and the occupation of the property, it is not liable to POAT

IHTM44036 - Pre-owned assets: excluded transactions: the contribution condition - outright gift of money
For the purposes of the contribution conditions relating to land and chattels, the contribution by a person to the acquisition of any property is an excluded transaction in relation to the chargeable person if it was an outright gift of money to the other person (and ‘other person’ here means the person referred to in FA04/Sch15/Paras 3(3) and 6(3)) and was made at least 7 years before the earliest date after 5 April 2005 on which the chargeable person

occupied the land, or
had possession or use of the chattel, FA04/Sch15/Para 10(2)(c).

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Re: IHT planning...what have you done?

#474931

Postby Dod101 » January 21st, 2022, 8:20 am

I think Eboli is taking much too narrow a view of this matter which is why HMRC is not following up on these cases. The POAT rules are obviously intended to pick up cases where HMRC is being cheated of significant IHT by elaborate schemes to avoid tax, not where a parent hands over property to a child say without any reservation of benefit and years later when Mum is left on her own in a large property is offered the opportunity to move in with the the donee child. The POAT rules simply cannot apply there whatever he says. End of.

Dod

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Re: IHT planning...what have you done?

#475067

Postby scrumpyjack » January 21st, 2022, 2:01 pm

Dod101 wrote:I think Eboli is taking much too narrow a view of this matter which is why HMRC is not following up on these cases. The POAT rules are obviously intended to pick up cases where HMRC is being cheated of significant IHT by elaborate schemes to avoid tax, not where a parent hands over property to a child say without any reservation of benefit and years later when Mum is left on her own in a large property is offered the opportunity to move in with the the donee child. The POAT rules simply cannot apply there whatever he says. End of.

Dod


As I noted above Finance Act 2004 specifically excludes the case where Dad gives daughter cash, she buys a house and he lives there as long as at least 7 years elapsed between giving the cash and the occupation.

For the purposes of paragraphs 3(3) and 6(3) (the contribution condition) the provision by a person (“the chargeable person”) of consideration for another’s acquisition of any property is an “excluded transaction” in relation to the chargeable person if—

(c)the provision of the consideration constituted an outright gift of money (in sterling or any other currency) by the chargeable person to the other person and was made at least seven years before the earliest date on which the chargeable person met the condition in paragraph 3(1)(a) or, as the case may be, 6(1)(a),

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Re: IHT planning...what have you done?

#475142

Postby Lootman » January 21st, 2022, 5:02 pm

Dod101 wrote:I think Eboli is taking much too narrow a view of this matter which is why HMRC is not following up on these cases. The POAT rules are obviously intended to pick up cases where HMRC is being cheated of significant IHT by elaborate schemes to avoid tax, not where a parent hands over property to a child say without any reservation of benefit and years later when Mum is left on her own in a large property is offered the opportunity to move in with the the donee child.

Yes I had always thought that POAT specifically takes aim at various sophisticated avoidance schemes that have been dreamt up by accountants. The target is not ordinary families making end-of-life residential and care decisions.

Moreover to my mind reserving a benefit for oneself is an explicit and affirmative act AT THE TIME OF THE GIFT. It is not something that should be retrospectively inferred just because thirty years later my daughter invites me to live in her granny flat due to my impairment.

So if the taxman in practice does not enforce POAT unless there is some egregious evasion or avoidance going on, then that seems like a common sense approach for them to take. My accountant, who used to work for the taxman, will sometimes say things like "Don't worry about X as HMRC never look at that anyway and aren't bothered". Knowing which tax rules are not enforced is priceless knowledge as that is never publicised for obvious reasons.

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Re: IHT planning...what have you done?

#475203

Postby Eboli » January 21st, 2022, 7:56 pm

As genou has already commented about the "practical approach" adopted here, I can't be bothered non curat lex!

I have better things to do.

Eb.

Lootman
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Re: IHT planning...what have you done?

#475250

Postby Lootman » January 22nd, 2022, 1:02 am

Eboli wrote: I can't be bothered non curat lex. I have better things to do.

Maybe you do have better things to do. But then, here you are . . .

And by the way the full phrase you are quoting there is "de minimis non curat lex". In other words the courts (and the taxman) do not concern themselves with trivial infractions.

More generally despite the dismissive attempts of both you and genou, who are both accountants it would seem, to disparage real-life practical experience, I think you miss the broader point here. TLF, and TMF before it, are predicated on the idea that the average Joe is smarter than the "professionals" who, in many ways, have their own self-serving agendas.

Meaning that you want us to feel scared of GWROB, POAT and the like because it implies we should pay you to immunise ourselves from that risk. But as many of us with practical real-life experience have explained, that risk is exaggerated and mostly irrelevant to the everyday situations that we find ourselves in.

This debate and disagreement is healthy, is just what TLF is about, and you should welcome it rather than dismiss it and hide behind your "professional" status.


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