R. M. OWEN (INSPECTOR OF TAXES) v. EDWARD SASSOON.

[1951] 1 Lloyd's Rep. 266

CHANCERY DIVISION.

Before Mr. Justice Wynn-Parry.

Revenue - Income tax - Assessment - Lloyd's underwriter not ordinarily resident in United Kingdom - Securities deposited in accordance with Trust Deed-Interest on securities- Exemption under Schedule C - Liability under Schedule D-Trust Deed entered into by respondent whereby, in consideration of his being admitted an underwriting member of Lloyd's and as a guarantee against his default, he was required to deposit securities to be held by Lloyd's as trustees-Deposit of Colonial Stock and Savings Bonds to form Trust Fund- Annual income from securities at free disposal of respondent except in case of default in payment of insurance claims -Premium Trust Deed entered into between respondent and other members of his Lloyd's underwriting syndicate and Lloyd's whereby all premiums, etc., were to be held upon trust and to be exclusively available for the payment of any claims, etc., in his underwriting account-No default by respondent in his underwriting account-Interest received on Colonial Stock and Savings Bonds-Whether forming part of profits of underwriting business and chargeable to tax - Income Tax Act, 1918, Schedule D, Case I-Finance Act, 1940, Sects. 21, 60.