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The main and indeed fatal flaw in HMRC's "view" of usufructuary
dismembemens is exposed in Keyhaven's Tax Planing Review Volume 7
published on 28th October, 2018.
A copy is available on the Overseas Chambers News and Press page
under English articles at
FRENCH USUFRUITS AND S.43(2) IHTA 1984 Carrying
burning coals to Newcastle in the flickering light of
Philipson-Stow v. IRC
Pleasen note the important point which was omitted ifrom the
final edit that the creation of a chose in action over foreign and
English land (re. Berchold) is an immovable chose in action,
not an equitable movable chose in action.