Dunsby v HMRC [2022] WTLR 81

Wills & Trusts Law Reports | Spring 2022 #186

Mr Mark Dunsby participated in a tax avoidance scheme devised and promoted by De Sales Promotions Ltd. As part of the scheme, in March 2013, Mr Dunsby had a company, of which he was sole shareholder and director, issue a non-voting share to a non-resident individual, Mrs Fiona Gower. Mrs Gower established a trust and settled the share in the trust, with the benefit of any dividends being for Mr Dunsby, and Mr Dunsby’s company paid £200,000 as a dividend in respect of the settled share. As a result of the scheme, Mr Dunsby received £195,400. HMRC issued a closure notice dated 31 March 201...

Clipperton & anr v HMRC WTLR(w) 2021-08

Wills & Trusts Law Reports | Web Only

Interest-in-possession trusts: A balancing act

Emma Cooper explores how to set up dividend policies for companies wholly owned by trustees of a life interest trust ‘Trustees who hold the entire issued share capital of a company, or who otherwise control it, are in a very different position from investors with minority holdings, as they have the power to decide the …
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