In March the settler made 2 transfers of shares in the
But transfers not registered until June.
Estate duty would only be payable if effective date of
transfer was found to be June.
Court of Appeal held no duty payable as settler had
done everything in his power to effect transfer.
Milroy v Lord did not compel court to negative the
conclusion that, pending registration, the settler was a trustee of the legal
interest for the transferee.