References: 15 TC 693, [1930] UKHL 2, [1931] AC 212
Links: Bailii, Bailii
Coram: Lord Buckmaster, Viscount Dunedin, Lord Warrington of Clyffe, Lord Tomlin, Lord Thankerton
Ratio: 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 of a benefit devised or bequeathed to him or her under the will.
Jurisdiction: England and Wales
This case cites:
- See Also – Baker v Archer-Shee HL (Bailii, [1927] UKHL 1, [1927] AC 844, [1926] 11 TC 749)
‘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 . .
(This list may be incomplete)
This case is cited by:
- Cited – Anson v Revenue and Customs SC (Bailii, [2015] UKSC 44, [2015] 4 All ER 288, [2015] STI 2019, [2015] BTC 21, 17 ITL Rep 1007, [2015] STC 1777, Bailii Summary, UKSC 2013/0068, SC, SC Summary)
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 . .
(This list may be incomplete)
Last Update: 07 July 2019
Ref: 248479
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