Da Vinci owed?

THE PROVISIONS OF FA 1986 s 102 introduced into the inheritance tax regime a prima facie charge to inheritance tax where the donor reserved possession and enjoyment of the gifted property during the seven years prior to his death. The so-called 'gifts with reservation' (GWR) dispensation is supplemented by FA 1986 Sch 20 which included in paragraph 6 a 'prospectus' designed to negate the prima facie charge to tax contained in s 102 in circumstances where — during the vulnerable period — the donor has afforded 'full consideration in money or money's worth' for the reserved benefits.
This prospectus and thus the planning opportunities dealt with in this article survived the introduction of the 'pre-owned assets' income tax charge under FA 2004
s 84 and Sch 15 (which of course 'bites' in regard to Ingram carve out chattels arrangements and the...