When a company listed on the London Stock Exchange makes a public issue of shares or rights, the issue may be underwritten. The underwriter, for a commission, agrees...
Life Assurance Premium Relief. Reg. 10(6), Income Tax (LAPR) Regulations 1978.Under this system of relief, withdrawn on 13 March 1984, individual policyholders deducted income tax from life assurance...
Interest. Whether or not “income arising”. Receivability without receipt.The taxpayer opened two deposit accounts with Barclays Bank plc on 12 March 1990, and deposited substantial amounts in them....
Statutory interpretation. Carry back of surplus ACT. McGuckian principle applied.The taxpayer was incorporated in 1993. Under Agriculture Act 1993, it was permitted to take over the trade and...
Industrial Buildings Allowance. The taxpayer, which operated cash and carry warehouses, sought to obtain IBAs on the ground that the buildings were used “for the purposes of a...
Corporation tax. Accounting periods. ‚ÄúWithin the charge to tax‚Äù Рs.832(1) ICTA 1988.Decision of Vinelott J (Click here) upheld. ACT paid on a dividend cannot be carried back...
Income tax. Schedule D. Farming / woodlands.
The taxpayer grew Christmas trees. On a nine-acre site, coniferous trees were planted: mainly Norway Spruce, but also two other species not...
Income tax. Schedule E. PILONs (Payments in Lieu of Notice).Two employees had notice periods of six months. The contract of employment provided for PILONs to be made, saying...
Inheritance tax. “Carve-out” leases. Failed implementation.
Lady Ingram had conveyed property to a nominee, who then purported to grant her a lease of 20 year term. The freehold reversion...
In a landmark decision for pension funds, the Special Commissioners held that the sub-underwriting activities of the Post Office and BT schemes did not constitute trading within Case...
