Buzzoni v HMRC

The Upper Tribunal decision in Buzzoni v HMRC has now been released. The Upper Tribunal has dismissed the taxpayer’s appeal against the decision of the First Tier Tribunal to the effect that the gift of a leasehold flat was a gift with reservation of benefit by reason of the covenants entered into between the donor and the donee. The decision ( Buzzoni v HMRC (2012) Civ 1268) will be discussed fully in the November issue of Farm Tax Brief/Trusts and Estates.