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Capital Gains

And with much loss of tax relief: DAVID WHISCOMBE reports the Special Commissioner's decision in Drummond.
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)
The Budget 2007 changes may put disincorporation on the agenda for many small businesses, warns PETER RAYNEY
RICHARD CURTIS reviews the sixth and seventh Public Bill Committee debates on the Finance Bill 2007.

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

 

OWEN CLUTTON argues that the new 'permanent establishment' test for trustee residence in TCGA 1992, s 69(2D) is too onerous.
Smallwood v CRC
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