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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: gifts with reservation: tracing: introduction

The property given by the donor may be retained unchanged by the donee until the donor’s death.

Alternatively, the donee may, for instance, sell the property, give it away, or add to it, or the donee may die. In situations such as these you have to be able to establish the property comprised in the gift for two purposes

  • to decide whether there is a reservation

and if so

  • to determine the property subject to the GWR claim.

The rules you should apply (within FA86/Sch20 Para 2) depend on whether

  • the gift is to the donee absolutely and of either
  • cash (IHTM14372)
  • other property (IHTM14373)
  • the property is settled by the gift (in which case, see the separate instruction on tracing settled property (IHTM14401)).