Chancery Division.

Judgment delivered 26 April 1983.

Income tax – Surtax – Foreign discretionary settlements – Shares assigned to non-resident trustees – Income of shares comprised in settlements – Power of settlor to appoint committee of protectors and trustees – Trustees’ power to apply income from shares with consent of committee – Whether power of settlor constituted power to control application of income – Whether income taxable as income of settlor under sec. 478Income and Corporation Taxes Act 1970, sec. 478(5)(e).

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