The rules that stop a donor giving property away on paper while keeping its benefit — GROB, POAT and associated operations, and how each closes a different escape route.
A gift only works for inheritance tax if the donor truly lets go; these provisions decide when a transfer fails that test. This chapter starts with the gifts with reservation of benefit rules — the gateways that trigger them, the 'entire exclusion' test and the value brought back into the estate — before turning to the exceptions for full consideration and shared occupation, and what follows when a reservation ceases before death. It then covers the pre-owned assets tax, the income tax charge that catches arrangements GROB misses, the property it applies to and the election that switches it off. The chapter closes with the associated operations doctrine and the planning that remains untouched, including the standard gift exemptions and outright gifts into discretionary trusts.
