and this is exactly why you shouldn't comment on things you clearly don't understand!
A direct quote from the FTT:
"The majority view reflects the argument that the controversial monies received by the employees were not paid to them as their absolute entitlement.
"The legal effect of the trust/loan structure is sufficient to preclude this. Thus the payments are loans, not earnings, and so are recoverable from the employee or his estate."
Which is almost exactly what I said above, without my wonderful turn of phrase of course.