Foyle's law

ONCE UPON A time I worked in the Inland Revenue's company tax division with the title 'Technical Division (Distributions)'. I have since maintained an interest in the distributions legislation
so I was naturally interested in the Noved case (see Noved Investment Company v HMRC [2006] SSCD 120 (SpC 521)).

Background

Noved originally carried on the business of selling books (Foyle's bookshop in London) but having transferred that business out to another company is now an unlimited investment company. When Christina Batty (née Foyle) died she owned 60% of the shares of the company which she left on general charitable trusts. The executors effected her bequest by establishing a UK resident company as a charitable foundation.
In an agreement between the executors the other shareholders the foundation and the appellant company her shares were transferred to...