Allison Plager

The High Court allowed the Revenue's appeal in Commissioners of Inland Revenue v Mallender and others (executors of Drury-Lowe, deceased).

Land charged for the purposes of a bank guarantee obtained by a Lloyd's underwriter was claimed as a business asset for the purposes of business property relief on his death. The Court disallowed it, saying that only the guarantee was relevant, not the asset that supported it.

ALLISON PLAGER reports the changes made by the Finance Act 2001 to the tax treatment of transfers of shares in life insurance products.

THE TAX TREATMENT of insurance contracts tends to inspire fear into those unused to dealing with them. In essence, insurance contracts are taxed according to whether or not they are qualifying and, as most policies taken out by taxpayers are qualifying, the general practitioner is unlikely to have to deal with non-qualifying contracts on a regular basis.

ALLISON PLAGER peruses a recent survey of information technology usage in accountancy practices.

ALLISON PLAGER summarises two recent cases.
Advantageous buyback
The OMEGA Group is a plc which trades in computer software. It had an exempt approved pension scheme established in 1949. Exempt approved status under section 592, Taxes Act 1988 gives the fund exemption from income tax on income derived from investments, provided that the Revenue is satisfied that such income is held for the purposes of the scheme. Mercury Asset Management was the appointed discretionary fund manager for the scheme.

JOHN T NEWTH and ALLISON PLAGER summarise some recent cases heard by the Special Commissioners.

Relief in redundancy

The appellant company had carried on manufacturing businesses from various sites and through different divisions in Scotland. However, in August 1997 the entire share capital of the company was purchased by Fullarton Computer Industries Limited.

ALLISON PLAGER explores the little publicised relief available for expenditure on remediation of contaminated land.

Many a parent resorts to bribery to encourage their recalcitrant offspring to tidy their rooms. In a manner of speaking this is what the Government has done in respect of contaminated land. Although in this instance, the money is not given to the one who created the contamination, rather the one who performs the cleaning up operation.

ALLISON PLAGER reports a recent Special Commissioners' case.

No relief for therapy

The appellant, who was a doctor and psychiatrist, was required by his employer, the National Health Service, to undergo personal psychotherapy during his appointment. The National Health Service paid for half of the fees, but the appellant had to fund the balance. He therefore claimed the fees not paid by the employer in his self-assessment tax return.

ALLISON PLAGER summarises two recent cases.

Non-qualifying accountancy services