Court of Appeal backs taxpayers in 'landmark' Home Loan Scheme IHT ruling

The ruling, in HMRC v Elborne, confirmed that a Home Loan Scheme – also known as a Double Trust Scheme – implemented by the late Mrs Elborne was effective for IHT purposes, rejecting HMRC's appeal and upholding an earlier Upper Tribunal decision. Background on the case In 2003, Mrs Elborne sold her home to a trust in which she retained a life interest in possession in exchange for a promissory note of equivalent value. She then gifted the promissory note to a second trust benefiting her three children, while continuing to live in the property rent-free until her death in 2011. Th...