Home › Forums › Patrick Cannon › Beneficial Interest › Reply To: Beneficial Interest
23rd September 2010 at 7:18 pm
#449
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My thoughts entirely learned counsel.
Agree that beneficial ownership concept too blunt in this situation, but any lender to first party unlikely to appreciate this! Boxes to tick etc.
CGT disposal interesting point. Related to above of course. Maybe no disposal if never any transfer, but answer probably in Jerome v Kelly.
SDLT deemed market value rule also relevant in this scenario, but what is ‘subject matter’ exactly?
Some interesting issues here – would be good to get a discussion going amongst all you big brains.