88 Gains of dual resident settlements

88  Gains of dual resident settlements

(1)     Section 87 also applies to a settlement for any year of assessment beginning on or after 6th April 1991 if—

(a)     the trustees are [resident . . . in the United Kingdom during any part of the year], [and]

(b)     at any time of [such residence . . .] they fall to be regarded for the purposes of any double taxation relief arrangements as resident in a territory outside the United Kingdom, . . .

(c)     . . ..

[(2)     The [section

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