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Capital Gains

Sometimes it is right to go with your instincts, says NICHOLAS STRETCH in relation to the capital gains tax aspects of disposals of employee shares.
LEÓN FERNANDO DEL CANTO looks at how Spanish tax reforms will affect British owners of holiday homes in Spain.
KEN MOODY carves his way through the mire of recent legislation relating to employment-related securities in a quest to discover the meaning of 'grandfathering'.
MIKE TRUMAN identifies the real culprits in artificial tax avoidance schemes.
COLIN KENDON considers the impact of EMI options on the sale of company shares.

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).

Recent HMRC research looked into people's perceptions of capital gains tax and why they create trusts. ALLISON PLAGER reports.

Negligible values

HMRC have accepted the following security as having negligible value during November 2006 for the purposes of a claim under TCGA 1992, s 24(2).

 

JOHN WHITING assures us that the twelve days of Christmas have fiscal issues at every turn.
Artificial losses; CT avoidance; CFCs
PETE MILLER discusses a recent Special Commissioner's decision concerning the tax charge on a company leaving a group.
Only or main residence is a wonderful relief, but a complex one, especially if you are married or in a civil partnership, says AILEEN DEENEY.
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