United Kingdom House of Lords Decisions

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Cite as: 26 TC 23, [1944] UKHL TC_26_23

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(1) Commissioners of Inland Revenue v Williams's Executors ; (2) Williams's Executors v Commissioners of Inland Revenue - [1944] UKHL TC_26_23 29 February 1944

At a general meeting in 1922 of a private company dealing in bloodstock, it was resolved that all reserve funds (which consisted entirely of undistributed profits of the company) should be the joint property of members of the company pro rata to their shareholdings. In 1927, W became a director of the company, acquiring 750 shares out of the 3,000 issued and paying £1,901 10s. for a one-fourth share of the reserve fund. In view of the value of their personal connexions, each director took out an insurance policy against death or disablement by accident; the company paid the premiums and was the beneficiary under the policies. In February, 1938, one of the directors died as the result of an accident and the company received £15,000 from the insurance company.

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