Realise this is pretty technical in nature, but would appreciate any views on the below.
I'm considering buying shares in a listed US company (Norton LifeLock). The business will in a few months' time distribute c. 50% of today's share price as a special dividend. This dividend will be treated as a return of capital for US tax purposes and as such does not constitute income. However, as a UK shareholder, can I use that argument with HMRC and treat the dividend as a reduction in the CGT cost basis? GIven it's a US business, who decides for HMRC as to whether the dividend is income or return of capital? If the process of proving this to HMRC is too onerous I should stop thinking about buying these shares outside of an ISA or SIPP - it doesn't make any investment sense is the div is treated as income.
Many Thanks in advance.
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