Business tycoon Sir Charles Clore was born poor in London's East End in 1904 and died rich in Monaco in 1979. Head of Sears Holdings, he built the Hilton Hotel in London and owned Selfridges, and gave generously to hospitals as part of a wide range of philanthropic activities.
Was his domicile England or Monaco? The tax man (HMRC today, it was the Inland Revenue then) argued that it didn't really matter: Clore should be deemed domiciled for tax purposes in England even if his actual domicile was Monaco.
Sir Charles had two children, a son Alan and a daughter, Dame Vivien Duffield, a philanthropist and major benefactor of, among others, the Royal Opera House. The Clore Gallery at Tate Modern, home to a vast collection of the works of JMW Turner, was built largely with money from the Clore Foundation.
Clore has prepared two wills, one for his Monaco assets, and a general will for everything else, including assets in a third jurisdiction, Jersey.
But probate was a long time coming, held up by several legal disputes. One case turned on capital transfer tax involving assets sent from England to Jersey. Clore's son Alan argued that his father's domicile was Monaco. If the laws of Monaco rather than England applied, Alan would automatically be entitled to a share in his father's estate.
Numerous, complex and costly hearings were held in Jersey and England. Conclusion: Clore was deemed domiciled in Britain.
'I'm his only child and naturally the main beneficiary. He told me that some years ago. He may have left something to Dennis as a way of thanking him for his services over the last twelve years, and I think he did mention that. He also told me that he was leaving two million pounds to the Combe Island Trust, to be used in part to have another cottage built and named after him. I don't know whether he's altered his will recently. If he had, he didn't tell me.... If he has cut the Trust out of his will I'll be glad.'
P D James, The Lighthouse (2005)
