Stephen Oliver QC and James Kessler for the taxpayer.
Foreign possessions – Income arising from possessions out of United Kingdom – Trustee – Liability – Discretionary settlement – Principal beneficiaries not resident in United Kingdom – No beneficiary entitled to income as it accrued – Trust assets and income administered outside United Kingdom – No income remitted to United Kingdom – Three trustees only one of whom resident in United Kingdom – Whether single United Kingdom resident trustee liable for assessment to income tax on income derived from trust assets – Income and Corporation Taxes Act 1970, ss 108, 114.