Some ordinary shares in a family company are held in a discretionary trust.
assuming the the buy back meets the requirements, if the shares are purchased directly from the Trust, will capital treatment apply
or
if the shares are appointed to the beneficiaries and a gift holdover election is made
then, in the hands of the beneficiary, will the buy back by the company of these same shares still qualify to be treated as capital, rather than an income distribution.
Thanks you
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