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Home / Simons-Taxes /IHT, trusts and estates /Part I3 Lifetime transfers /Division I3.7 Pre-owned assets tax (POAT) /POAT—existing arrangements / I3.751 POAT—'Ingram' schemes
Commentary

I3.751 POAT—'Ingram' schemes


IHT, trusts and estates

A typical example of a lease carve-out (or 'Ingram') scheme is where:

  1. Ìý

    •ÌýÌýÌýÌý Mr A transfers title to his property to a nominee

  2. Ìý

    •ÌýÌýÌýÌý the nominee then grants Mr A a 20-year lease of the property at a peppercorn rent

  3. Ìý

    •ÌýÌýÌýÌý the encumbered freehold reversion is then gifted to Mr A's son, and

  4. Ìý

    •ÌýÌýÌýÌý Mr A continues to occupy the property

Such schemes were found to be effective in Ingram1

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