‘The ultimate question in this Appeal turns upon the description which in income tax phraseology ought properly to be applied to the moneys paid during the two years in question by the Trust Company of New York to the order of Lady Archer-Shee, the respondent’s wife, at Messrs. J. P. Morgan and Company’s Bank there. None of these moneys have been received in the United Kingdom. It is that fact which, if his contention as to their true description be correct, enables the respondent to say that he is not liable to pay income tax in respect of them, either in whole, in part, or at all.’
Judges:
Viscount Sumner, Lord Atkinson, Lord Wrenbury, Lord Carson, Lord Blanesburgh
Citations:
[1927] UKHL 1, [1927] AC 844, [1926] 11 TC 749
Links:
Jurisdiction:
England and Wales
Cited by:
See Also – Archer Shee v Garland HL 15-Dec-1930
The parties disputed the taxpayer’s liability to income tax on income coming due to her on an American based family trust.
Held: A beneficiary in a fully administered deceased estate has an equitable interest in property which is the subject . .
Cited – Anson v Revenue and Customs SC 1-Jul-2015
Interpretation of Double Taxation Agreements
This appeal is concerned with the interpretation and application of a double taxation agreement between the United Kingdom and the United States of America. A had been a member of an LLP in Delaware, and he was resident within the UK, but not . .
Lists of cited by and citing cases may be incomplete.
Income Tax
Updated: 10 July 2022; Ref: scu.251629