FTTTx CAPITAL GAINS TAX – whether distributions to beneficiaries from new resident trust to be matched to gains in original offshore trust – HMRC accepted that flip-flop mark II scheme effective so gains not arising in new trust – whether s 97(5) TCGA 1992 applied so that the distributions to beneficiaries from the new trust were nevertheless ‘from . . indirectly’ the original trust – yes as on facts new trust was essentially and viewed realistically a continuation of the original trust – assessments upheld
[2013] UKFTT 366 (TC)
Bailii
Capital Gains Tax
Updated: 17 November 2021; Ref: scu.513478
