The Special Commissioners held on 7 February 2007 in The Trustees of the FD Fenton Will Trusts v HMRC [2007] UKSPC SPC00589 that a contribution to the capital of a Delaware company by its UK resident sole shareholder was not deductible expenditure for capital gains purposes. The case concerned an investment by UK resident trustees in a company incorporated in the US state of Delaware. The entire share capital of the Delaware company consisted of no par value shares, all of which were acquired by the trustees for a nominal consideration. In subsequent years and at various times when the...