INHERITANCE TAX - discretionary settlement - 10-year charge – whether the proceeds of
sale of scrip dividend shares to which s.249 ICTA 1988 applies are deemed to be income not
only for the purposes of ICTA 1988 but also for the purposes of trust law generally and for
the purposes of Inheritance Tax
PRECEDENT – whether the Upper Tribunal is bound by a prior decision of the High Court
Appeal of taxpayer dismissed.