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An appeal concerned a flip flop scheme specifically the liability of offshore settlements to capital gains tax in respect of trustees’ gains in the year of assessment.
The taxpayer set up a trust in 1994 with the initial sum of £10 and himself as life tenant. The trustee company was resident in the Isle of Man. Next the taxpayer settled 31 250 shares from Streamline Holdings Ltd in the trust and the trustee transferred them to Broomhurst a Manx company.
In 1998 Broomhurst accepted an offer from Jarvis plc for the shares and received loan notes in exchange.
In March 1999 the taxpayer established another trust this time with UK resident trustees.
Two days later the trustee of the 1994 trust borrowed £1.433 million from Coutts and three days after that the trustee appointed £1.386 million to the trustees of the...
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