The use of trusts as vehicles to carry on small and medium size businesses and as investment vehicles has expanded rapidly since the demise of the Ralph Report recommendations on trusts. Mooted changes never made it past the discussion stage and trusts, in all forms, were once again recognized as a flexible, tax effective and relatively cheap vehicle to be utilized in particular circumstances. A growth in tax litigation has also arisen in recent years and one senses that the Taxation authorities and taxpayers are testing the boundaries of tax trust law.
This paper examines developments in some of these areas.