Commentary

I5.132 Case law—the settlor

IHT, trusts and estates

I5.132 Case law—the settlor

I5.132 Case law—the settlor

The following are the main examples of persons held to be settlors for income tax purposes who would probably be held to be settlors for IHT purposes if the dispositions involved or resulted in assets being held as settlements (I5.111):

  1.  

    •     A controlling shareholder who secures the issue of shares in the company to other persons on advantageous terms: Coleman1

  2.  

    •     A life tenant who surrenders the life interest: Buchanan2

  3.  

    •     Someone who pays interest on a loan from the trustees where the borrowing facility would have continued to be available interest-free if the relevant dispositions had not been entered into: Leiner3. This case

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial