This appeal concerned the first periodic charge which fell due on a Jersey-resident discretionary trust established by the settlor, Mr Dreelan (‘the Settlor’) on 21 June 2001 (‘the 2001 Settlement’).
The Settlor transferred £100 to Barclays Wealth Trustees (Jersey) Limited (‘the Trustee’) to hold on trusts in broad discretionary form. The beneficiaries were the Settlor, his spouse and his children then living or born during the trust period. At this date the Settlor was not domiciled in the UK for IHT purposes.
The Trustee lent part of the settled funds to a wholly-owned Je...
On 21 June 2001 the settlor, who was then non-domiciled in the UK, settled cash derived from a Jersey bank account on the trusts of a Jersey-resident discretionary trust called the Michael Dreelan Trust (MDT). The settlor became deemed domiciled in the UK for inheritance tax purposes from the beginning of the tax year 2003/04. Subsequently, on 4 April 2008, the settlor and others set up another settlement called the Dreelan Brothers Joint Trust (DBJT) and 25,000 ordinary shares in Qserv Limited were transferred from the MDT. These were later sold for cash that was UK situs property. On 2...
Mr Gilchrist settled property on trust on 17 May 1993. Under the terms of the trust, he was entitled to a life interest in the trust property. On 4 June 1993, the trustees exercised an overriding power of appointment to appoint 20% of the fund (the appointed fund) out of the main fund, on discretionary trust for the benefit of members of Mr Gilchrist’s family. Mr Gilchrist and his spouse were excluded from any benefit in the discretionary trust. Mr Gilchrist then gifted £44,000 to the trustees. The trustees used the funds to contribute to Whitecroft Limited, in which the trust held...
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