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HMRC internal manual

Capital Gains Manual

Absolute entitlement: part of trust fund: other assets

In Stephenson v Barclays Bank Trust Co Ltd, Walton J said that as regards shares in a private company in very special circumstances, and possibly mortgage debts, the person with a vested interest in a share of the property might have to wait for sale before he could call upon the trustees to account to him for his share. The principle of Crowe v Appleby therefore may apply to other indivisible assets. A good example would be an Old Master painting or valuable antique, or indeed a single share in a company.