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Settlor Winston creates an offshore trust in an offshore jurisdiction. He transfers the legal title to the trustee, Kezron, to hold property on trust for

Settlor Winston creates an offshore trust in an offshore jurisdiction. He transfers the legal title to the trustee, Kezron, to hold property on trust for certain beneficiaries. Unbeknown to Kezron, Settlor Winston intends to create one set of rights and obligations different from those contained in the Trust Deed. The rights and obligations in the trust deed are to give the Revenue the impression that Settlor Winston is not the owner of the property transferred to the trust when in facts he intends to retain ownership. Kezron conscientiously carries out his duties in accordance with the trust. The Revenue alleges that the trust is a sham.

Advise the revenue

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