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Capital Gains

SHARON ANSTEY considers the application of the Ramsay principle to capital loss schemes after Barclays Mercantile Business Finance Limited v Mawson [2005] STC 1.
RICHARD CURTIS considers some ingredients of property taxation.

In the final article of this series of three on self assessment enquiries, ROBERT MAAS FCA, FTII discusses section 19A and paragraph 27 notices and appeals.


SECTION 19A OF the TMA 1970 is a fairly narrow information power. As such the issue of a section 19A notice is unlikely to be a disaster provided that it is appealed against within the 30 day time limit.
Information falls within s 19A only if it meets all of three conditions:

WILL SILSBY BA, CTA takes a sideways look at the tax treatment of online auctions.

IT WAS MY own fault. Scanning through eBay just before going to sleep is never as relaxing as studying the Income Tax (Trading and Other Income) Act 2005 but I could not have envisaged the consequences.
'Mr and Mrs Line are here to see you', said the receptionist in that careful tone that implied so much more.

JOHN ENDACOTT explores the taper relief anomalies of business and non-business assets.


I WAS INTERESTED to read the recent articles in Taxation by Mike Truman under the titles 'Flatly Incredible' (14 July 2005, page 406) and 'Flatly incredible II' (8 September 2005, page 621). These concerned the position where an asset is used partly for business purposes and partly for non-business purposes as far as capital gains tax taper relief is concerned.

ELIZABETH FOTHERGILL considers the effect of residence on the income tax liability of savings and investment income.

PAULA TALLON runs through tidying up a company's affairs in preparation for a sale.

DAVID JEFFERY highlights some planning points pertaining to capital gains tax main residence relief.

CAPITAL GAINS TAX has been with us for forty years and so has the only or main residence relief of what is now TCGA 1992, s 222, et seq. Of course, it is a commonplace and in most cases a straightforward relief; nevertheless, in practice there are borderline cases and opportunities for effective planning.

MIKE TRUMAN looks again at taper relief for part disposals and finds some planning possibilities that he wishes he hadn't...

JARLATH McCLOSKEY examines the income and capital gains tax consequences of the commercial occupation of woodlands.


JULIE BUTLER provides a practical guide to the tax implications of the new single payment scheme.


THE INTRODUCTION OF the Single Farm Payment is considered by many to be the most fundamental change to farming since the repeal of the 'corn laws'. It essentially means that farming subsidies are no longer 'coupled' to production, but are based on area and historical entitlement. The burning question has been: how will this impact upon the taxation of farmers and landowners?

MARTIN DAWSON and CHRIS HOLDEN contemplate the global nature of the capital gains tax legislation.


WILLIAM SHAKESPEARE WROTE in As You Like It, that 'All the world's a stage'. While he could not have contemplated just how wide the territorial scope of the UK's capital taxes legislation would extend some 400 or so years later, the words are opportune when considering the subject.

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