I move: "That the Dáil agree with the Committee in Resolution No. 21." There is another type of case to which Section 1 of the Finance Act of 1931 applies in which the danger of loss of duty arises: that is to say, where A, a life tenant, receives payment not out of the funds of the company, but from some other source— for instance, directly from B, the remainder man. It is thought that as the section stands at present the words "by such company" and "from the company" where they occur in paragraph (c) and paragraph (d) (iii), respectively, might make it possible for an evasion of the sort to which I have referred to take place —that is, that the payment would not be received by the company but, in fact, would be made by some other person having an ultimate interest in the estate, and that therefore because of that they might be able to evade the section. The alteration proposed in the Resolution is designed to ensure that where the payment received by the life tenant is, in fact, part of the same transaction as that whereby the property is transferred to the company that the estate will be deemed to pass on death in exactly the same way as before.
In Committee on Finance. - Financial Resolution No. 21—Death Duties.
Question put and agreed to.