David Jeffery

The current tax year could be very beneficial for investments in the SEIS, says DAVID JEFFERY, but there are pitfalls

DAVID JEFFERY warns of the perils of ignoring the relevant factors when calculating small companies relief

A recent development in company law has eased decision-making in relation to reducing share capital. DAVID JEFFERY explains

DAVID JEFFERY highlights some planning points pertaining to capital gains tax main residence relief.

CAPITAL GAINS TAX has been with us for forty years and so has the only or main residence relief of what is now TCGA 1992, s 222, et seq. Of course, it is a commonplace and in most cases a straightforward relief; nevertheless, in practice there are borderline cases and opportunities for effective planning.

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DAVID JEFFERY of WJB Chiltern reviews some topical issues relating to the determination of residence status.

DAVID JEFFERY explains why care must be taken when a non United Kingdom domicile transfers assets to the United Kingdom.
SOME OF THE most treacherous legislative provisions in the Income Tax Acts are sections 739 to 746, Taxes Act 1988 (all statutory references in this article being to that Act unless otherwise stated), particularly when they are applied to persons who are not domiciled in the United Kingdom but are ordinarily resident there.

The concept of ordinary residence could very well be done without, argues DAVID JEFFREY.
It is commonplace to say that our taxation system has become stifled by increasing complexity. As legalisation grows, attempts by practitioners to retain an overall grasp of the system become virtually impossible. There are opportunities to simplify the fundamentals of the system, but sometimes we cling to familiar concepts even when they have outlived their usefulness.

The concepts of residence and ordinary residence contain various inconsistencies which should be reviewed, argues DAVID JEFFERY.
OFTEN, WORKING IN taxation, we can get attached to familiar concepts. Over time, we gain a working knowledge of what various concepts mean and some practical experience of how they apply. They become a comfortable part of the scenery, and we overlook the fact that they are full of unchallenged imperfections. Such are the concepts of both 'residence' and 'ordinary residence'.