421C - I think you have muddled up your quotes - not that it matters.
Fair enough, but I think for the time being we will have to disagree on this one. I have spent a lot of my professional time involved with trusts as have the legislators!
Distinguishing one trust from another (given both conduct themselves properly) because you dont like the way one trust is operating over another will find very little favour with the Courts, would be perverse and more importantly, it would be very difficult to draft legislation to have this effect.
There is a good analogy. A UK limited company may comprise effectively one person or a thousand. It would be a great idea to tax the individual the same as any other individual but the company with 20 shareholders differently. Good luck.
However, as interesting as the debate, the problem will be whether anyone wants to take a chance on their interpretation of the legisaltion as you say over the ramp checker's interpretation.
It doesnt matter to me as I have said but it will be interesting to see exactly what is intended.
421C - as ever your posts are very interesting and informative, dont misunderstand me, you could well be correct, I am playing devil's advocate.