1.   Under California law the stock dividends were attributed to the life tenant.

2.   This could apply where A is a life tenant under a foreign trust and A was the settlor.

3.   That will comprise a potentially exempt transfer regardless of where the life tenant resides or where his ordinary place of residence is or where he is domiciled.

4.   The fact that the life tenant is domiciled in the United Kingdom when he dies or gives his life interest away is irrelevant.