Court of Appeal.

Judgments delivered 21 June 1985.

Capital transfer tax – Capital distribution – Excluded property – Beneficiary domiciled and ordinarily resident outside UK – Government securities tax exempt while owned by foreigners – Creation of interest in possession in exempt government securities – Property previously comprised in settlement with beneficiaries domiciled and ordinarily resident in UK – Whether securities excluded property – Whether two settlements to be treated as one – Finance Act 1975, Sch. 5, para. 1, 6(2), 11(4), (11); Sch. 7, para. 3(2).

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