Section 255 notices are effective where money controlled by a non-resident's controller is denominated in foreign currency; the controller must retain sufficient foreign currency to cover the tax at prevailing exchange rates, and exchange rate risk thereafter falls on the non-resident taxpayer and the Commissioner, not the controller.
The full text is available to signed-in members, including the 3 later cases that cite this judgment.
1 of the 3 citing cases carry a classified treatment. How each court treated it is available to signed-in members.