Add to ORKGThe Raftland Trust 'washed' $4 million of trust distributions through a loss trust whilst the benefit of nearly all sums distributed was retained. 'Sham' characterisation was confirmed by the High Court for this otherwise legally enforceable transaction. The taxpayer's financial and fiscal objectives had impermissibly differed. This article examines the reasoning of members of the court and outlines some disturbing implications
The 1955 U.S. Supreme Court decision in Commissioner v. Glenshaw Glass Co. defined income as all “un...
The Act of State doctrine generally dictates that American courts not sit in judgment with respect t...
There is a longstanding debate about whether courts should enforce contract terms purporting to limi...
The late economic crisis has given impetus to trusts settled in furtherance of unlawful purposes, na...
This article analyses the interpretation of the phrase “received by, accrued to or in favour of†...
This article examines the decision of the House of Lords in Total Network SL v Customs and Excise Co...
This article considers the doctrines of sham trusts and alter egos currently causing some controvers...
This article analyses the interpretation of the phrase “received by, accrued to or in favour of” in ...
In Caparo Industries Ptc. v. Dickman, the House of Lords turned its attention again to the age-old p...
Why would a prudent taxpayer make an acquisition at a price in excess of fair market value? This inq...
In IES Industries, Inc. v. United States (2001), the 8th Circuit Court of Appeals reversed the distr...
This article examines the decision in FCT v Clark and its implications. On appeal, the Full Federal ...
Should the donor\u27s specific interests or potentially conflicting theoretical economic principles ...
The recent swaps litigation in the United Kingdom has focused attention on the restitutionary conseq...
AIB Group (UK) plc v Mark Redler & Co Solicitors examined the issue of appropriate remedies availab...
The 1955 U.S. Supreme Court decision in Commissioner v. Glenshaw Glass Co. defined income as all “un...
The Act of State doctrine generally dictates that American courts not sit in judgment with respect t...
There is a longstanding debate about whether courts should enforce contract terms purporting to limi...
The late economic crisis has given impetus to trusts settled in furtherance of unlawful purposes, na...
This article analyses the interpretation of the phrase “received by, accrued to or in favour of†...
This article examines the decision of the House of Lords in Total Network SL v Customs and Excise Co...
This article considers the doctrines of sham trusts and alter egos currently causing some controvers...
This article analyses the interpretation of the phrase “received by, accrued to or in favour of” in ...
In Caparo Industries Ptc. v. Dickman, the House of Lords turned its attention again to the age-old p...
Why would a prudent taxpayer make an acquisition at a price in excess of fair market value? This inq...
In IES Industries, Inc. v. United States (2001), the 8th Circuit Court of Appeals reversed the distr...
This article examines the decision in FCT v Clark and its implications. On appeal, the Full Federal ...
Should the donor\u27s specific interests or potentially conflicting theoretical economic principles ...
The recent swaps litigation in the United Kingdom has focused attention on the restitutionary conseq...
AIB Group (UK) plc v Mark Redler & Co Solicitors examined the issue of appropriate remedies availab...
The 1955 U.S. Supreme Court decision in Commissioner v. Glenshaw Glass Co. defined income as all “un...
The Act of State doctrine generally dictates that American courts not sit in judgment with respect t...
There is a longstanding debate about whether courts should enforce contract terms purporting to limi...