Revocable transfer: transferor's income included if transfer allows re-transfer or re-assumption of control. A transfer is deemed revocable where it allows re-transfer of any part of the income or assets to the transferor, or grants the transferor a right to re-assume power over any part of the income or assets during the lifetime of the beneficiary or transferee; 'transfer' includes settlements, trusts, covenants, agreements or arrangements and this concept governs inclusion of such income under the clubbing rules.