“…ower. 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 trustee. I do not consider that the wording of section 43…”
“…There was also reference to the position in relation to a bare trust in the next case, Inland Revenue Comrs v Silverts Ltd [1951] Ch 521. The issue there was whether a company was one “the directors whereof have a controlling interest therein” for the purposes of paragraph 11 of Schedule IV to t…”