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No rollover
In 1995 the husband sold his shares in two companies making large capital gains. He and his wife owned shares in R Ltd a property investment company and B Ltd a trading company which was a qualifying company for TCGA 1992 s 164G (rollover relief). By April 1996 they each owned one subscriber share in R Ltd and the husband had subscribed for the remainder of the £100 share capital fully paid. He had also lent the company £900 000 as loan capital. By April 1996 the husband owned £80 and the wife owned £20 of the share capital in B Ltd and by November the share capital was 1 000 £1 shares. The husband controlled both companies. It was also agreed that the companies were connected within the meaning of s 286 that the husband was connected with...
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