Lifetime transfers: loss to estate less than value of property given
- remains part of the deceased’s estate, (IHTM04029)
- includes excluded property, (IHTM04251) or
- if the transferee pays the expenses (other than any IHT on the transfer) incurred by the transferor in making the transfer, IHTA84/S164.
Example 1A puts £200,000 into a settlement where the trusts are for A to life with remainder over. The £200,000 remains part of A’s estate, so although there is a disposition, (
Example 2Under the Will of T, property is settled on L for life with remainder to R. R gives the reversionary interest (
IHTM16000) to L. The reversion is an item of property which has value. But it is excluded from the charge (IHTM04281) which is disregarded in considering whether the disposition has given rise to a loss to R’s estate. The disposition is not a transfer of value.