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United Kingdom House of Lords Decisions

You are here: BAILII >> Databases >> United Kingdom House of Lords Decisions >> Chinn v Hochstrasser (Inspector of Taxes) [1980] UKHL TC_54_311 (11 December 1980)
URL: http://www.bailii.org/uk/cases/UKHL/1980/TC_54_311.html
Cite as: [1981] 1 All ER 189, [1981] STC 1, [1980] UKHL TC_54_311, 54 TC 311, [1981] AC 533, [1981] 2 WLR 14, [1980] TR 467

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Chinn v Hochstrasser (Inspector of Taxes) [1980] UKHL TC_54_311 (11 December 1980)

Capital gains tax - Avoidance - Foreign trustees - Appointment to beneficiary of interest in shares contingent on survivalfor three days - Immediate sale by him to foreign company coupled with contract to repurchase shares on fourth day - Whether scheme effective to avoid apportionment of gain to beneficiary - Finance Act 1965 (c 25), ss 25(3) and 42(2) and Sch 7, para 13(1).

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