Chancery Division.

Judgment delivered 22 February 1983.

Capital gains tax – UK resident beneficiary of non-resident trust – Apportionment of gains – Whether apportionment should be made in proportion to the benefits received – Whether case should be remitted to Commissioners for finding of further facts bearing on apportionment – Finance Act 1965, sec. 42(2)Capital Gains Tax Act 1979, sec. 17(2).

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