Mark Buzzoni (Executor of the estate of Lia Kamhi deceased) and Others v The Commissioners for HM Revenue and Customs: [2012] UKUT 360 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Proudman on 19 October 2012.
Read the full decision in .
Whether s. 102(1)(b) of the Finance Act 1986 (gift with reservation) applies to a gift of a reversionary underlease containing covenants from the donee mirroring covenants in the donor鈥檚 head lease. Application of Ingram v. IRC. Decision of the First-tier Tribunal upheld: such covenants do constitute a reservation within the section.
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Published 1 December 2016