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Ingram Part 2: A Dangerous Development

The Ingram decision affects many existing arrangements made with potential inheritance tax savings of millions of pounds.
In the second article examining the decision John Newth reflects on the wider implications and the disturbing developments in case law affecting tax planning arrangements.

1 November 1997

Ingram Part 2: A Dangerous Development

The Ingram decision affects many existing arrangements made with potential inheritance tax savings of millions of pounds.
In the second article examining the decision John Newth reflects on the wider implications and the disturbing developments in case law affecting tax planning arrangements.

The traditional view

The traditional view of both the professions and the Inland Revenue has been that tax planning arrangements, fully disclosed in all respects, represent valid legal tax avoidance, if cleared by the Revenue.

Motive and artificiality did not prejudice this approach in the past. Indeed the professions used two tax cases

enacted more than 60 years ago as their mandate. One was Ayr. Pullman Motor Services v CIR 15 TC 754, and the other Duke of Westminster v CIR 19 TC 490. where Lord Tomlin stated:

'Every man is entitled if he can to order his affairs so that the tax attaching under th...

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