Funds in bank accounts in the appellant’s name were held in her capacity as bare trustee for her parents-in-law and her appeal against discovery assessments in respect of tax on interest and gains and also penalties for failure to notify liability were allowed. 

The appellant, a midwife in the NHS, was married with three children. At the relevant time, the youngest child was three years old, and as childcare was so expensive the appellant worked night shifts so that she could look after the child during the day. The appellant’s husband worked for the UK branch of the Singapore Bank Oversea-Chinese Banking Corporation Limited (OCBC). 

HM Revenue and Customs (HMRC) opened an enquiry into the appellant’s tax position, based on information received that she had over $900,000 in an account in her name with Standard Chartered Bank in Singapore (and previously