The Weekly Law Reports
[1965] 1 WLR 1133
[COURT OF APPEAL.]
INLAND REVENUE COMMISSIONERS
v.
GEOFFREY BOOTH BATES.
INLAND REVENUE COMMISSIONERS
v.
ERNEST BATES.
1965 May 11,
12;
June 2.
June 2.
Lord Denning M.R., Davies and Russell L.JJ.
Revenue
— Surtax
— Settlement
— Trust fund
— Shares in trading company
— Payments by company to settlor of capital sums
— Whether company a “body corporate connected with the settlement”
— Reasonable part of company's income distributed in relevant years
— Whether company within statutory definition
— Statutory scheme for treating as part of income of settlor capital sums paid by company to extent of “income available”
— Carry-forward scheme
— Whether taxpayer liable to surtax on relevant parts of capital sums
—
Income Tax Act, 1952 (15 & 16 Geo. 6 & 1 Eliz. 2, c. 10), ss. 245, 408, 411 (4) (a) (b).