Trust Fund / Inheritance Tax

It's worth noting that countries don't always agree on the facts, or on the conclusions to be drawn from them. And sometimes they simply refuse to meet as "competent authority" as the treaty provides. The taxpayer's solution is to sue in tax court (special commissioners in Britain, I guess). But tax courts tend to be parochial. Here's an interesting case:

Caron v. The Queen:

(taxpayer held taxable in Canada since that's where his family lived; even though he lived and worked in France (and was taxable there) his 'centre of vital interests' was Canada). In estate taxation the tocsin too-clever tax lawyers was the Dorrance case, and the limits of double (triple, etc.) taxation were set out in Texas v. Florida, the case of the estate of Ned Green, son of Hetty Green (who, in the first and second decades of the 20th Century, was America's richest woman, I think):

In re Dorrance, 115 N.J.Eq. 268, 170 A. 601 (Prerogative Ct. 1934), aff'd mem. 13 N.J.L. 3625, 184 A. 743, cert. denied, 298 U.S. 678 (1936); In re Dorrance's Estate, 309 Pa. 151, 163 A. 303 (1932), cert. denied, 288 U.S.

617; Texas v. Florida, 306 U.S. 398:

Moral: states can double and triple tax up to the total value of an estate, but they can't tax 101% or more. In the USA anyway. That's for dead people. For living people, there is the Multistate Tax Compact and other multilateral and unilateral allowances that permit tax credits; in some states (NY and Michigan come to mind) Canadian provincial taxes are allowed as a credit. But I digress.

Dorrance was the heir to the Campbell's soup fortune.