CAPITAL GAINS TAX – Computation of gain – Second hand life assurance policy – Surrender proceeds brought into computation of chargeable event gain for income tax – Whether surrender proceeds to be excluded as disposal consideration for CGT purposes – No – TCGA 1992 s37(1)CAPITAL GAINS TAX – Acquisition consideration – Wholly and exclusively for the acquisition of the asset – Second hand life assurance policies acquired for ¬¨¬£210,000 above surrender value as part of tax avoidance scheme – Whether entire consideration incurred for acquisition of the policies or as part of pre-ordained tax avoidance scheme – Whether alternatively the ¬¨¬£210,000 was consideration for acquisition of the policies – No – Appeal dismissed – TCGA s.38(1)Patrick Way and Hui Ling McCarthy appeared for the AppellantTimothy Brennan KC and Nicola Shaw appeared for the Respondent
Jason Drummond v. The Commissioners for Her Majesty’s Revenue and Customs – Special Commissioners
GITC is sad to report the death of our Head of Chambers, Mr Milton Grundy who passed away at the weekend.
Gray’s Inn Tax Chambers is deeply saddened by the passing of our founding member and Head of Chambers, Mr Milton Grundy
28 Nov 2022
Gray’s Inn Tax Chambers is deeply saddened to learn of the death of Her Majesty Queen Elizabeth II.
We join the nation in mourning and our condolences are with the Royal Family.
09 Sep 2022
The 2022 GITC Review is now available
If you would like to be added to the mailing list for future issues of the GITC Review, please send an email to Jane.Fullbrook@taxbar.com.