Barclays Wealth Trustees (Jersey) Limited v. Commissioners for Her Majesty's Revenue and Customs, [2017] EWCA Civ 1512

On June 21, 2001, an Ireland-domiciled individual (“Dreelan”) paid £100 to a New Jersey trustee (with successors, the “Trustee”) to hold...

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In the course of describing submissions of the taxpayer’s counsel with which he ultimately agreed, Henderson LJ stated (at para. 47):

In support...

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