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The following are the main examples of persons held to be settlors for income tax purposes who would probably be held to be settlors for IHT purposes if the dispositions involved or resulted in assets being held as settlements (I5.111):

1. Ìý

   •ÌýÌýÌýÌý A controlling shareholder who secures the issue of shares in the company to other persons on advantageous terms: Coleman¹

2. Ìý

   •ÌýÌýÌýÌý A life tenant who surrenders the life interest: Buchanan²

3. Ìý

   •ÌýÌýÌýÌý Someone who pays interest on a loan from the trustees where the borrowing facility would have continued to be available interest-free if the relevant dispositions had not been entered into: Leiner³. This case shows that 'settlor' is not confined to someone who provides capital

4. Ìý

   •ÌýÌýÌýÌý Someone who enters into an employment contract with a company owned by the trustees of a settlement whereby he receives a small salary and the bulk of the payments for his services is the