Revenue and Customs Commissioners v. First Nationwide, [2012] BTC 99, [2012] EWCA Civ 278

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Summaries

Summary Under

The fact that the payment of a dividend out of the share premium account of a Caymans company reduced the capital that would have been...

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Summary Under

capital v. income character of distributions/payment of dividend out of share premium account

The taxpayer, in cooperation with two banks, a Cayman Islands corporation and its parent, implemented the following series of transactions:

The...

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