“…sider that in any real sense he can be said to have voting power. The Court of Appeal, in two cases I have mentioned (Inland Revenue Comrs v J Bibby & Sons Ltd [1944] 1 All ER 548 and Inland Revenue Comrs v Silverts Ltd [1951] Ch 521), were clearly impressed by the appeal to the common sense and economic reality of the case of a bare tru…”
“…any was one “the directors whereof have a controlling interest therein” within the meaning of s.13(9) of the Finance (No 2) Act 1939. Both the Court of Appeal ([1944] 1 All ER 548) and the House of Lords answered in the affirmative on the facts of the case, but the position as regards a bare trust was left open. In the Court of Appeal, L…”