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The treatment of reversionary interests in cases involving a foreign element is complicated.

For information on the rules generally see Divisions I5.7. For HMRC general guidance on reversions see IHTM16231 onwards.

For information on the other categories of excluded and exempt property for IHT see I9.311.

The relevant statutory provisions are as follows.

The general rule ¹ is that a reversionary interest² is excluded property unless:

1. Ìý

   •ÌýÌýÌýÌý it has at any time been acquired, either by the person entitled to it or by a person previously entitled to it, for a consideration in money or money's worth³, or

2. Ìý

   •ÌýÌýÌýÌý it is one to which the settlor or his spouse or civil partner is or has been beneficially entitled⁴, or

3. Ìý

   •ÌýÌýÌýÌý it is an interest expectant on the determination of a lease of property which is for life or lives, or for a period ascertainable only by reference to a death and not granted for a full consideration in money or money's worth⁵;