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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’s head lease. Application of Ingram v.
IRC. Decision of the First-tier Tribunal upheld: such covenants do
constitute a reservation within the section.
Published 1 December 2016