ONE OF THE most effective US political planning strategies of recent years plus numerous coaching books have all been founded around the so-called 'KISS' principle — 'Keep it simple stupid'. The deliberately provocative logic behind this is that the provider of an idea should first think about the sensible pragmatic and straightforward solution rather than overcomplicating matters. This is particularly relevant in the field of inheritance tax planning.
Over recent years we have seen numerous schemes and avoidance devices ranging from those used by Lady Ingram (see Ingram & Palmer-Tomkinson (Lady Ingram's Executors) v CIR [1999] STC 37 — the 'lease-shearing' scheme) to double trust home loans. Most of the more aggressive schemes relating primarily to family homes have been severely curtailed by the introduction from 6 April 2005 of the pre-owned asset rules. While there are still innovative and useful planning devices available for saving...
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