UNITED STATES SUPREME COURT DECISIONS ON-LINE

An American trust, created in the United States under Connecticut law and administered in the United States by an American trustee, the beneficiaries of which are British subjects and residents and which retains capital gains income realized in this country, is not exempt from federal income tax on such gains by virtue of a provision of the Income Tax Convention between the United States and the United Kingdom which exempts capital gains of a "resident of the United Kingdom." Pp. 373 U. S. 49-56.

299 F.2d 565, affirmed.