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Routier and anor v HMRC

In Routier and anor v HMRC [2014] EWHC 3010 (18 September 2014) the High Court found that a disposition in a will was subject to IHT as it was not a gift to charity.

Mrs Coulter died in Jersey in October 2007 leaving the residue of her estate to a trust for the benefit of the Parish of St Ouen to provide homes for the elderly of the parish. The disposition was subject to conditions and provided that if they were not fulfilled by the parish a disposition should instead be made to Jersey Hospice Care.

HMRC did not accept that the gift was exempt from IHT. A deed of variation of the trust provided for an absolute gift of £10 000 to Jersey Hospice Care and an absolute gift of the residue to the appellants to use for the purpose of the construction of...

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