Midland Bank Executor and Trustee Co v Inland Revenue Comrs

Subject Matter

REVENUE — Estate duty — Property passing on death — Property chargeable — Derivative trust — Gift of income of trust fund to beneficiaries of “A” trust for 21 years subject to discretionary power of accumulation — Gift over to persons to be appointed under “B” trust — Rights of “A” beneficiaries relinquished by deed and court order in favour of “B” beneficiaries subject to similar power — Appointment of “B” beneficiary to interest in income of trust fund — Death of beneficiary before expiration of 21 years — Finance Act, 1894 (57 & 58 Vict. c. 30), ss. 1, 2 (1) (b).