A valid disposition could be made by a member of a religious order even if all the covenanted income was paid into a common fund. Revenue Commissioners v HI 1984 III ITR 242
The minimum payment is made from the date of the first payment to the date of the last payment as provided for in the investment. IRC v St Luke’s Hostel Trustee 1930 TC 682
While the money must be applied for the covenantee’s benefit, he does not need to have a beneficial interest in the payment. Action Aid v Revenue Commissioners 1997 V ITR 392
The definition of a settlor and a settlement was outlined in EG v MacSamhrain 1957 II ITR 352.
