Chancellor Confirms New Rules on Uses Will End Tax Avoidance Through Trusts Once and for All

26 May 2026

WESTMINSTER, 1290 — Robert Burnell, Chancellor to King Edward I, has announced new measures targeting the practice of “uses,” the device by which a landowner transfers legal title to a trusted associate (the feoffee) who holds the land on behalf of the true beneficiary, and confirmed that the reforms will end tax avoidance through trust arrangements once and for all. 

The Chancellor, addressing the Exchequer, confirmed that uses had for several decades permitted wealthy landowners to direct the profits of their estates to family members who held no legal title and therefore owed the Crown nothing. Upon the death of a feoffee, his portion passed to the surviving feoffees rather than to his heirs, meaning no feudal dues arose. The Crown collected no relief. No wardship fees were paid. The landowner’s non-working wife and younger sons received the benefit of the estate at rates that, in the Chancellor’s estimation, were not what Parliament had in mind. 

“The arrangement is quite deliberate,” Burnell told the Exchequer. “The landowner retains all enjoyment. The feoffee holds the title. The feudal incident falls between them. This cannot continue.” 

The new rules will require that the profits of land held under a use be assessed as income of the person who truly benefits, eliminating the practice of splitting estate income among family members specifically to reduce what is owed to the Crown. The Chancellor described the measure as closing a loophole that had been widening since approximately 1220. 

Burnell noted that the Court of Chancery, which enforces these arrangements in conscience rather than at common law, had shown no sign of ceasing to do so, and that the lawyers advising landowners on the use of uses were, in the main, the same lawyers advising the Crown on how to stop them. 

Critics noted that the Chancellor’s predecessor had said substantially the same thing in 1267, and that the Church, the barons, and the better part of the baronage were currently operating under use arrangements and had not indicated any intention to restructure. 

The Chancellor expressed confidence that the new rules would resolve the matter definitively. He died the following October. The use continued. 

This article is a parody. The use is not.