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Nature of shares

14 September 2015
Issue: 4518 / Categories: Tax cases , Admin
CRC v J Blackwell, Upper Tribunal (Tax and Chancery Chamber), 13 August 2015
The taxpayer held class A B and C shares in Blackwell Publishing (Holdings) Ltd. In 2003 after an unsuccessful takeover attempt by Taylor & Francis Group plc the taxpayer entered into an agreement with Taylor & Francis in relation to his A shares in return for £1m. 
 
In 2006 John Wiley & Sons Inc made an offer for Blackwell for a higher sum than Taylor & Francis had offered in 2003. Taylor & Francis offered to release the taxpayer from the 2003 agreement if he paid them £25m. 
 
In November 2006 the taxpayer entered into a new agreement with Taylor & Francis. This released him from the 2003 agreement and in return he paid Taylor & Francis £25m of which Wiley provided £7.5m and he provided the balance.
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