This appeal related to an inheritance tax notice of determination dated 22 May 2013 in respect of the estate of Dr Olive Scott (Olive) who died on 4 March 2007. Olive was predeceased by her husband Professor James Scott (James). The appellant, Malcolm Scott (Malcolm), was her surviving son and co-executor...
The appellants had established a remuneration trust by a trust deed dated 26 March 2010 and of which they were the protectors. As such, they had the power to appoint and remove trustees, including Bay Trust International Ltd (the trustee). On the day of its establishment, the appellants applied to the trustee for loans of £550,000 which were duly advanced the same day...
James Albert McLaughlin (taxpayer), who was UK resident, engaged in a marketed planning scheme to avoid tax on a capital gain that he had made on the sale of a business. The scheme involved the acquisition by exchange of shares for overseas registered loan notes issued by two subsidiaries of Skandia UK Ltd (loan notes)...