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The website version of 'Harry's game' (Taxation, 8 February 2007, page 160) has been amended with regards to capital gains tax taper relief because there is no need to apportion for periods of ownership before 5 April 1998 when calculating Harry's gains on completion (TCGA 1992, Sch A1 para 2(2)(a) refers). Harry therefore qualifies for full business asset taper relief on the initial consideration settled in cash and QCBs (and on the earn-out if taxed on completion due to Marren v Ingles).
The website version of 'Harry's game' (Taxation, 8 February 2007, page 160) has been amended with regards to capital gains tax taper relief because there is no need to apportion for periods of ownership before 5 April 1998 when calculating Harry's gains on completion (TCGA 1992, Sch A1 para 2(2)(a) refers). Harry therefore qualifies for full business asset taper relief on the initial consideration settled in cash and QCBs (and on the earn-out if taxed on completion due to Marren v Ingles).
The gremlins also got into the final sentence of the 'Spouse transfers' section, which has now been amended to read: 'To satisfy these, Harry needs to transfer at least 25% of his shares to Heather if she was not an employee/officer of Target (or 5% if she was) to avoid her taper relief being tainted.'
However, this has thrown up another issue regarding the correct entitlement to taper relief for a spouse following such a transfer of shares and we will return to this in a future issue.
