The taxpayers had placed shares in the defendant company in foreign trusts.
Held: Under the general law, each brother had made five separate settlements; that s 43 did not reduce the five settlements to one settlement; that there were five charges to Inheritance Tax; and that, to bring the property within the charge to tax, it was neither appropriate nor necessary to consider whether the five settlements were created by ‘associated operations’.
Judges:
Park J
Citations:
[2002] STC 872
Statutes:
Jurisdiction:
England and Wales
Citing:
Appealed to – The Commissioners of Inland Revenue v Rysaffe Trustee Company (CI) Limited CA 20-Mar-2003
The taxpayers had repeatedly settled shares in the taxpayer company in foreign trusts. The Commissioners sought to use the special legislative regime, imposing a periodic charge to Inheritance Tax on discretionary trusts.
Held: Inheritance Tax . .
Cited by:
Appeal from – The Commissioners of Inland Revenue v Rysaffe Trustee Company (CI) Limited CA 20-Mar-2003
The taxpayers had repeatedly settled shares in the taxpayer company in foreign trusts. The Commissioners sought to use the special legislative regime, imposing a periodic charge to Inheritance Tax on discretionary trusts.
Held: Inheritance Tax . .
Lists of cited by and citing cases may be incomplete.
Inheritance Tax
Updated: 11 April 2022; Ref: scu.180027
