How can I make PPR available by using an implied trust?
A owns a property in his sole name which he purchased so his son could live there as a student. He now wishes to gift the property to his son but there is a substantial CGT liability. I understand that if he proves a constructive trust to HMRC, the son will be able to have his own PPR as a beneficiairy of the trust. I believe that HMRC will want to see that the arrangement for the son operated in practice in exactly the same way that a trust would have.
My question is how do I go about trying to establish a constructive trust with HMRC?
Large & Gibson