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    <title>1964 (5) TMI 49 - HOUSE OF LORDS</title>
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    <description>Interest earned on clients&#039; money held by a solicitor in a fiduciary capacity remained beneficially owned by the clients unless informed clients agreed, expressly or by implication, or a legally sufficient professional custom transferred that ownership. The practical difficulty of allocating interest among many clients did not change the proprietary position. The same principle applied to interest arising from loans made out of clients&#039; funds. As the interest did not belong to the solicitor, it could not be treated as his earned income, and the claim to earned income relief failed.</description>
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    <pubDate>Tue, 26 May 1964 00:00:00 +0530</pubDate>
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      <title>1964 (5) TMI 49 - HOUSE OF LORDS</title>
      <link>https://www.taxtmi.com/caselaws?id=192879</link>
      <description>Interest earned on clients&#039; money held by a solicitor in a fiduciary capacity remained beneficially owned by the clients unless informed clients agreed, expressly or by implication, or a legally sufficient professional custom transferred that ownership. The practical difficulty of allocating interest among many clients did not change the proprietary position. The same principle applied to interest arising from loans made out of clients&#039; funds. As the interest did not belong to the solicitor, it could not be treated as his earned income, and the claim to earned income relief failed.</description>
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      <pubDate>Tue, 26 May 1964 00:00:00 +0530</pubDate>
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