M L Salinger and J L Kirby v HMRC

Cathya Djanogly

In M L Salinger and J L Kirby v HMRC [2016] UKFTT 677 (11 October 2016) the FTT found that the transfer of a reversionary interest had not been a transfer of value for IHT purposes.

Mr Salinger had entered into tax planning arrangements to reduce the amount of IHT payable on his death. The arrangements had involved the transfer of a reversionary interest he held in an Isle of Man trust to the Salinger Family Trust (‘the DSFT’) of which Mr Salinger’s children M L Salinger and J L Kirby were the trustees. Mr Salinger had died on 27 February 2011 and M L Salinger and J L Kirby had been appointed executors of his estate.

HMRC had issued a determination on the basis that IHT was due in relation to the transfer of the reversionary interest. The executors contended that the reversionary interest was excluded property...

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