Principles.tax (beta)
General principles for tax law

- Requires a degree of certainty (not subject to discretion)

 

"The meaning is, to some extent, one of impression and we feel that as a matter of the ordinary use of English the wore “will,” in the context. imports a degree of certainty. It suggests rigidity rather than flexibility. And it seems to us to be pushing the ordinary usage of English altogether too far to say that a person “will” become entitled to property if he attains 21 or marries when his contingent interest can, at any time, be totally destroyed at the absolute discretion of the trustees and solely for the benefit of third parties." (Inglewood v. IRC [1983] STC 133, CoA)

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