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The Trustees of the F D Fenston Will Trusts v. Commisioners for HM Revenue and Customs

CAPITAL GAINS TAX – Computation of gains – Expenditure – Shares – Capital contributions to Delaware Company – Whether incurred “on the asset” – Yes – Whether reflected in the state or nature of the asset the time of disposal – No – Appeal dismissed – TCGA 1992 s.38(1)(b)

David Goldberg QC and Hui Ling McCarthy appeared for the Appellant