“…I now come to the decision of the House of Lords in St Aubyn v Attorney-General [1952] AC 15. It confirmed two alternative, but independent, claims to estate duty following the death of Lord St Levan in 1940. The claim which matters for present purpose…”
“…he gift”, the same could not be said of Lord Simonds, who used it as a touchstone throughout his discussion of the claim to estate duty on the 50,000 shares at [1952] AC 15, 26-30.…”
“…d forms an integral part of the property which is given away. The nearest that he comes to considering a case of that character is, I think, in his discussion ([1952] AC 15, at 50) of “a man who creates a rentcharge in his own favour upon property which is in his absolute disposition and then makes a gift of that property subject …”