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HMRC internal manual

Capital Gains Manual

Death of person with interest in possession: example

For example, A is entitled to 3/4 of the income of the trust fund and B is entitled to1/4. The trust fund consists of 1,000 shares of equal value in each of four companies. OnB’s death B2 is entitled to 1/4 of the capital, but the trustees have an express power ofappropriation. If the trustees appropriate 1,000 F Ltd shares to B2, rather than 250shares in each company, then the method described above enables the trustees to be treatedas if the deemed disposal on death was of 1,000 F Ltd shares, with the remaining sharesretaining their original cost.