Gabriel Jones died on 14^th May 2022. His will leaves his main residence to his son, 100,000 in cash to a registered UK charity, and the rest of his estate to his daughter.

Gabriel's wife died last year. Her estate was valued at 300,000. Her will provided for cash of 50,000 cash to each of her two children, and the rest of her estate to Gabriel. She had never made any lifetime gifts.

The following further information is relevant:

Gabriel's lifetime gifts

Donee	Date	Details
Nephew	15th May 2012	Cash of 10,000
Relevant Property Trust	1st December 2016	Cash of 475,000. Gabriel agreed to pay any tax associated with the transfer.
Daughter	10th April 2017	Vintage car, worth 50,000 at the date of the gift, on occasion of her marriage.
Son	12th April 2017	Portfolio of quoted company shares, worth 50,000 at the date of the gift.

Assets and liabilities at the date of Gabriel's death:

		Notes
Main residence	490,000
Second property in Spain	45,000	Additional costs of administering this foreign property were 8,000, including Spanish Inheritance Tax of 4,000.
Shares in GJ Ltd	178,000	Gabriel set up this company many years ago and always owned 100% of the shares until his death.
Mortgage on main residence	(70,000)
Income tax liability	(18,000)
Gambling debt	(4,000)
Chattels and personal effects	35,000
Cash	200,000

Required:

1. Explain the classification of lifetime gifts and how they are charged to Inheritance Tax ('IHT'). With specific reference to Gabriel's lifetime transfers, discuss the relevant reliefs, claims and exemptions which can be used to mitigate any IHT due as a result of his death.

(31 marks)

1. Show the IHT due on each of Gabriel's lifetime gifts as a result of his death. State who is responsible for paying the tax and the date by which it should be paid.

(29 marks)

1. Calculate the IHT due on Gabriel's death estate. Explain any reliefs or deductions that are available. State who is responsible for paying the IHT to the HMRC and the date by which it should be paid.

(40 marks)