The appellant’s claim for holdover relief on a gift of business assets to a company he solely owned was not precluded by the fact that his wife (and children), who had no interest in the company, were non-UK resident and connected with him.
The appellant, a US citizen who was neither resident nor ordinarily resident in the UK, disposed of his interest (including goodwill) in a business carried on by a limited liability partnership (B), transferring it by way of a gift on 1 April 2010 to a new UK incorporated
