This paper examines different concepts of ownership and entitlement that are relevant for tax purposes. Topics covered include:
- Who is a "beneficial owner"?
- When does beneficial ownership change?
- Beneficial ownership v. equitable interests
- Bare Trusts and absolute ownership with refernce to TR 2004/D25 Buckles cases (1998) and CPT Custodian (2005)
- Connected or different concepts: "vested and indefeasible interests" and "present entitlement"