QuestionA UK wholly-owned trading subsidiary of a US holding company owns a freehold property.
The property has increased in value by nearly £1m since purchase.
It is intended that the US holding company will be taken over by an unrelated US company which does not want to retain the freehold property.
There are four shareholders of the US holding company one of whom is UK resident and domiciled.
The original intention was to form a new UK company with the same four shareholders and transfer the property into that company.
While a transfer within the group would be exempt under TCGA 1992 s 171 once the company leaves the group a capital gain would...
