Robert Venables QC and Amanda Hardy for the taxpayer.
Revenue — Capital gains tax — Disposal of assets — Bare trustees of land entering into contract to sell land — Before completion of contract beneficial owners assigning part of beneficial interest to non-resident trustee of overseas settlement — Bare trustees completing sale — Whether beneficial owners liable to capital gains tax on proceeds of sale belonging to overseas trustee — Whether date of contract date of disposal — Whether beneficial owners parties to disposal — Capital Gains Tax Act 1979 (c 14), s. 27(1)