..., 1965: this exempts from capital gains tax any gainmade on the disposal of (inter alia) a reversionary interest under a settlementby the person for whose benefit the interest was created or by any...beneficiary. On 20th March 1975 the settlor's reversionary interest was assigned toPendle. On 24th March 1975 Thun agreed to lend the appellant £543,600to enable him to buy the Gibraltar...presently consist (sic)" of £255,390 ". What he had bought, on the other hand, for £543,600 wasa reversionary interest in £600,000, subject to the trustee's power to advance 10...

...conveyanceof the equitable reversionary interest at all. It deals with the shares them-selves, not with any beneficiary's particular interest in them. The Com-missioners, however, arrived at their...equitable reversionary interest in thesettled shares : by his oral agreement of that date he created in his motheran equitable interest in his reversion, since the subject-matter of the agree-ment was...vendor became a constructive trustee of" his equitable reversionary interest in the trust funds for the Appellant. 4 " No writing to achieve that result was...

...trust - tax planning arrangement involving transfer of reversionary interest whether excluded property or whether acquired for consideration anti-avoidance case law whether a transfer of value...Arrangements involved the transfer of a reversionary interest in an Isle of Man ( IoM ) trust to the Donald Salinger Family Trust ( the DSFT ) Mr Salinger's children, Michael Lawton Salinger ( Mr Mike...as trustees of the DSFT ( the Appellants ). The determinations were on the basis that IHT was due, consequential upon the transfer of the reversionary interest to the DSFT. 5. The...

...Copyright Act 1956 ("the 1956 Act") to assign the reversionary interest in the copyright in his works, expectant on the termination of the period of 25 years from his death. I shall refer to this interest..., for convenience, as "the reversionary interest". Until the commencement of the 1956 Act on 1st June 1957 the answer was clear. Section 5(2) of the Copyright Act 1911 ("the 1911 Act"), whilst...reversionary interest in the assignee and that those rights would vest (notwithstanding any agreement to the contrary) in the author's personal representatives. The proviso to s.5(2) was preserved by...

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...Party of his reversionary interest in the subjects."The Pursuer's SubmissionsThe Defender's SubmissionsThe Third Parties' Submissions...CONSIDERING that the reversionary interest in the subjects is approximately 50,000 and the First and Second Parties have agreed that should the subjects be sold each party would receive the sum of TWENTY...FIVE THOUSAND POUNDS ( 25,000) STERLING, FURTHER CONSIDERING that the First Party wishes to raise funds on his share of the reversionary interest in the subjects to the extent of TWENTY FIVE THOUSAND...

...Facts: A distillery company having disponed their heritable estate in security of advances with a reversionary interest to the disponers, the heritable creditors...10th March. He meanwhile learned that B, another creditor, in order to secure a preference over the reversionary interest of the company, had raised a summons of adjudication which had been called on...February 18th, and of which the usual twenty days' intimation had been made on February 22nd; and further, had also rendered the reversionary interest litigious by recording a notice of litigiosity...

...has subsequently acquired the freehold reversionary interest and the sub-leasehold interests in the subject property. The claimant has an intermediate ground-leasehold interest for a term of 999 years...the freehold reversionary interest in the properties. The rental income received by the freeholder from the claimant was 8.08 per annum and the value agreed with the freeholder was 90, which equates...to a YP of 11.1. The transfer was effected on 30 October 2001. As a comparable, Mr Scott referred to the acquisition of the freehold reversionary interest in 50 and 52 Haydock Street, Newton-le-Willows...

...was not a reversionary interest (Re Fisher [1943] Ch 377 at 328-3 followed). Thus his rights did not fall to be disregarded altogether under paragraph 5 of Schedule 10 to the Income...not a reversionary interest (Re Fisher [1943] Ch 377 at 328-3 followed). Thus his rights did not fall to be disregarded altogether under paragraph 5 of Schedule 10 to the Income...not count as a reversionary interest in the property now owned by his former wife, and is therefore not to be completely disregarded as an asset of his, but it is to be valued at a discount reflecting...

... TC/2019/06569 INHERITANCE TAX - tax planning arrangement involving transfer of reversionary interest - whether excluded property - no - whether a transfer of value - yes...and ultimately the statements of case each being different).3.             The Arrangements involved the assignment of the reversionary interest of the reversionary beneficiary...(Reversionary Interest and Reversionary Beneficiary respectively) in the Marshall Trust (MTrust), a 150-year Isle of Man (IoM) trust, to PL who was then granted an option to become the income...

...); CIS/85/1992 6. a freehold interest in property subject to a lease or tenancy is a "reversionary interest" within the meaning of paragraph 5 of Schedule 10 to the...freehold interest in property subject to a lease or tenancy is not a "reversionary interest" within the meaning of paragraph 5 of Schedule 10. Held, by the Court of Appeal, unanimously...Ralph Gibson); a freehold interest in property subject to a lease or tenancy is a "reversionary interest" for the purposes of paragraph 5 of Schedule 10 to the Income Support (General) Regulations 1987...

...Support General Regulations "a reversionary interest", and accordingly, is to be disregarded for the purposes of calculating the capital of the claimant. 2. This is an appeal with the...reversionary interest might be in 1993 and, if his interest in this other house (which I will call "the house") was a reversionary interest, it would be disregarded under para. 5 of Schedule 10 to the...re-hearing. However, he did not accept that the claimant's interest in the house was a reversionary interest for the purposes of para. 5 of Schedule 10 of the regulations. But he did submit that the...

...Mrs M'Arthur entered into a contract not to deal with the reversionary interest with anyone else?It is certain that no obligation is imposed on the National Bank to advance any more...for it, nevertheless, as long as the National Bank remained the absolute unqualified disponees she could not treat for, or dispose of in any effectual manner, her reversionary interest. It...charge upon her interest in the reversionary right. But the question is whether Mrs M'Arthur, having bargained away and made an assignation of her reversionary right to the knowledge of the National...

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...said John Stewart (which interest is of a reversionary character) realised, and that it is the duty of the defender the said L. D. Stewart, as trustee acting under the said disposition and settlement of...the said James Stewart, and as his executor, to realise the said reversionary interest accordingly, and to pay to the pursuer such sum as she may in the course of the process to follow hereon be...found entitled to receive as a surrogaturnsurrogaturn for the income of the said reversionary interest between 19th December 1895 and the date when the price of the said reversionary interest shall be...

...Savers" (described as "the purchaser") and Investors Trustees (described as "the trustees") by which D he assigned the reversionary interest in the fund to First Investors and Savers...second step, the sale by the Appellant to a Jersey company (which I shall call "the purchaser") of a reversionary interest in the fund. It was carried out by a deed dated 4 April 1972 much of which I must...exemption conferred by para 13 of C Sch 7, which I have read. What are the tax consequences of the earlier sale of a reversionary interest? The Crown says that the...

...judgment below was solely concerned with the second. HSBC's basic contention was and is that, despite only having a reversionary interest in the carriages, it was entitled to recover the repair costs and...the full value of the lost coaches. Network Rail, in contrast, contended that as reversioner, HSBC was only entitled to recover in respect of any permanent injury to its reversionary interest and no...his reversionary interest;(2) that damage was essential to the tort of negligence and that unless there was damage to the reversionary interest no action would lie...

...a short term discretionary trust of the shares with reverter to settlor, and a subsequent assignment of the settlor's reversionary interest to trustees. Although the creation of the discretionary...trust would be a chargeable transfer for inheritance tax, if Mr Griffiths were to follow this advice and survive the subsequent assignment by seven years then the value of the reversionary interest in...discretionary trust period, on 3 February 2004 Mr Griffiths transferred his reversionary interest in the shareholding in Iota Properties to the trustees of the newly created Griffiths Family Trust...

.... The option was exercisable on payment of a sum of £100.(3) PL assigned his reversionary interest to the Kent Trust, a UK resident family trust set up for the purpose. The Kent....5. HMRC issued notices of determination on the basis that PL made a transfer of value when he assigned his reversionary interest to the Kent Trust. The notices of determination were made on the basis...that IHT was due either by PL's estate or by the Kent Trust. The Appellants contended that there was no transfer of value on the basis that: (1) The reversionary interest was excluded...