Share transfer completed without immediate register entry, preserving inter se rights and supporting the capital loss claim.

Executed share transfer forms delivered with the share certificates were treated as sufficient to complete the transfer between transferor and transferee, even though the company had not yet entered the transfer in its share register. Registration was required only for the transferee to enforce shareholder rights against the company, not to perfect the transfer inter se. On those facts, the transfer was regarded as complete between the parties, and the assessee was entitled to claim the capital loss.

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Issues: Whether the transfer of shares was complete and effective as between the transferor and transferee even though the transfer was not yet entered in the company's share register, and whether the assessee was therefore entitled to claim the capital loss.

Analysis: The transfer forms were duly executed and delivered along with the share certificates, and the transferee had sought registration of the transfer. The absence of immediate entry in the company's register did not, on these facts, render the transfer incomplete between the parties. The requirements governing transfer were treated as satisfied so far as the vesting of rights between transferor and transferee was concerned, while registration remained necessary only for the transferee to exercise shareholder rights against the company.

Conclusion: The transfer of shares was complete as between the parties notwithstanding non-registration in the company's books, and the assessee was entitled to the capital loss.

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