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INTERNATIONAL U.K. House of Lords

Leedale (Inspector of Taxes) v Lewis [1982] UKHL TC_56_501 (14 October 1982)

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Leedale (Inspector of Taxes) v Lewis [1982] UKHL TC_56_501 (14 October 1982)

Capital gains tax – Gains accruing to trustee resident outside the U.K. – U.K.-resident beneficiaries being both potential objects of discretionary power and having interests contingent on surviving to a specified day – Whether apportionment of gains amongst beneficiaries mandatory – Whether relevant to consider hardship – Manner of apportionment – Finance Act 1965, s 42.
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