In J Frye v HMRC (TC01916 – 4 April) a UK citizen (F) received a dividend of £159 559 from a Bahamian trust. F failed to declare this on his tax return and HMRC issued an assessment charging tax on it. The First-tier Tribunal upheld the assessment and dismissed F’s appeal.
Why it matters: The Tribunal upheld HMRC’s view that a substantial dividend from an overseas trust was chargeable to income tax and rejected the appellant’s contention that it should be treated as capital.
90a1d87b-c1b5-43c3-a720-cd324830adee.tmb-editorspic.jpg?sfvrsn=1b2d0a7e_1)
