Seesurrun & anr v HMRC [2014] UKFTT 783 (TC)

January/February 2015 #146

The appellants appealed against decisions by the respondent that income of certain non-UK entities (including settlements established in the Isle of Man) could be attributed to them pursuant to s739 of the Income and Corporation Taxes Act 1988 (ICTA), which concerns the prevention of avoidance of income tax by individuals ordinarily resident in the UK by means of transfer of assets abroad.

The appellants owned three companies which carried on the trade of providing residential care to the elderly in the UK (the UK companies). The UK companies operated from four p...

Silber v HMRC [2012] UKFTT 700 (TC)

January/February 2013 #126

By his will dated 12 May 1997, Martin Moses Menachem Lerner (deceased) divided his net residuary estate into ten equal shares between the appellant as to nine shares and the Chay Charitable Trust (CCT) as to one share. Subsequently, the deceased gifted £60,000 cash to the appellant and transferred in excess of £400,000 worth of quoted shares to the CCT. Following the deceased’s death on 21 October 1999, a disappointed beneficiary under a former will disputed the validity of the last will on the grounds of testamentary incapacity, but this was settled on 22 October 2001 on terms tha...