Mr. Robert Venables Q.C., who appeared for Mr. Kerr
Capital gains tax — Settlements — Deceased not resident in United Kingdom — Share of residuary estate accruing to his UK resident daughter — Trust effected by instrument of variation within 2 years of death — Trustee not resident in the United Kingdom — Capital payments made to daughter by trustee — Whether gains chargeable as daughter was settlor, or not chargeable as deceased was settlor — Finance Act 1965, ss 24(7), 24(11) and 42, Finance Act 1981, ss 80-85.