Summary : Gift holdover relief (under TCGA 1992, s 165) was precluded (under s 167(2)) on an individual’s gift of goodwill to a UK company, as control of the company was attributed to the transferor’s wife (among others) who were not resident or ordinarily resident in the UK. Background : The appellant, a US citizen who was […]
Summary : The appellant’s period of ownership of an apartment for private residence relief purposes (under TCGA 1992, ss 222, 223) began when he owned the legal and equitable interest in the lease of the apartment and the legal right to occupy it, being the date of legal completion of the purchase of the lease. His […]
Capital Gains Tax Returns can be a tricky concept to get your head around, so it’s a good job we’ve written this blog that explains everything as simply as possible. Read on to find out everything you need to know about Capital Gains Tax… What is Capital Gains Tax? Capital Gains Tax is a tax […]
If you keep up-to-date with news and the opinions of political leaders you’ll know that there has been a significant debate in recent weeks surrounding the taxing of Non Resident Landlords Property Investment including but not limited to Buy To Let Residential and Commercial Properties. With Boris Johnson and Liberal Democrat leader Vince Cable both stepping out […]
CAPITAL GAINS TAX | Shares And Securities Conversions Of QCBs And Non-QCBs To Be Treated Separately Chargeable gains on shares that had been frozen into loan notes did not escape capital gains tax when the loan notes were converted into other loan notes, which were qualifying corporate bonds. The appellants held between them 100% of […]
Summary : The appellants’ chargeable gain on the disposal of their CGT Private Residence Relief was reduced due to a larger ‘permitted area’, but a part of the gain also arose due to ownership seven years before occupation. Background : The appellants (husband and wife) bought land for £11,000 in July 1987. At that time, the only […]
