Questions concerning gifts with reservation (GWR) provisions are more likely to arise in connection with gifts of land than any other type of gift. A variety of factors contribute to this:
typically, land and buildings carry a high value and often comprise the major asset in an estate. Gifts of land, if effective for IHT, will result in a significant tax saving
although the land may be the most valuable asset in the estate, the property in question may be the donor’s home, or a second property which he is reluctant to give up entirely
often, there is an intention to keep land and buildings in the family when the owner dies, whereas other assets will be realised in cash. This makes it difficult to make a lifetime gift of the portion that is not needed
land and buildings which do not produce income, present an obvious candidate for disposal, enabling the donor to retain liquid investments
property, such as a house, cannot easily be divided
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