O’Leary v McKinlay (HM Inspector of Taxes).  BTC 37
Judgment delivered 7 December 1990.
Income tax – Emoluments of employment – Avoidance scheme – Interest-free loan from employer to trustees of Jersey settlement for benefit of employee domiciled outside UK – Money deposited in Jersey bank and interest paid to employee – Whether trust income emolument from employment taxable under Sch. E or income from foreign possession taxable under Sch. D, Case V on a remittance basis.