Capital Gains

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CGT avoidance

Following the Royal Assent to FA 2007, HMRC have published revised guidance on the capital gains tax targeted anti-avoidance rule (TAAR). The document, Capital gains tax — Avoidance through the creation and use of capital losses can be found on the Internet at www.hmrc.gov.uk/cgt/cgt-recent-developments.pdf and explains HMRC's interpretation of TCGA 1992, s 16A and how the legislation applies.

And with much loss of tax relief: DAVID WHISCOMBE reports the Special Commissioner's decision in Drummond.

MARGARET CONNOLLY demystifies the great private equity kerfuffle

MARK MCLAUGHLIN considers potential obstacles to obtaining capital treatment on a company purchase of own shares and reviews company law issues.

WILL SILSBY and IAN SMITH offer a novel contribution to the debate on private equity gains.

One share too few

The following decision concerned whether or not capital contributions paid to a company qualified as a deduction for capital gains tax.

PAULA TALLON flags up some common tax planning traps and opportunities.

Boparan (SpC 587)

Nicholas John Harding (SpC 608)

RICHARD CURTIS reviews the sixth and seventh Public Bill Committee debates on the Finance Bill 2007.

The Budget 2007 changes may put disincorporation on the agenda for many small businesses, warns PETER RAYNEY

Disclosed schemes

When asked about the number of direct tax schemes notified under the disclosure of tax schemes regime, John Healey said that for the period to 31 March 2007 over 1,450 direct tax schemes (income tax, corporation tax, capital gains tax and stamp duty land tax) and over 800 VAT schemes had been disclosed.
Hansard, 13 June 2007, vol 461, no 104, col 1124W

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