Correspondence from readers on topical subjects.

Come into the Parlour Maud

Martin Riley's alternative view of s 660A (Taxation 20 January 2005 page 361) is an example of all that is best in a magazine for professionals. It's a contentious view fairly expressed; the fact that I happen to disagree with almost all of it is neither here nor there.

But can I comment in more detail on just one point? Martin introduces the Parlour case to show that one's ability to earn income is indeed an asset which can be given away. But it is also surely cogent evidence in support of the view that transfers of income between husband and wife may not be settlements in the first place; and that therefore one never gets as far as s 660A.

Consider Mr Parlour. One can fairly assume that he did not initially...