Chancery Division.

Judgment delivered 4 March 1983.

Capital gains tax – Discretionary beneficiaries of trust with non-resident trustees – Assessment of past and current gains – Whether past gains should have been assessed in the years accrued – Extent of ‘scheme’ – Whether a separate settlement – How gains to be apportioned – Finance Act 1965, sec. 42 (2) and (3)(b).

  These were appeals and cross appeals from a decision of the Special Commissioners regarding assessments to capital gains tax for the year 1976/77.

  The taxpayers were UK resident beneficiaries of a settlement controlled by non-resident trustees.

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