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...
Tax avoidance through the transfer of assets abroad. Sections 739 and 741 ICTA 1988.(1) On the natural meaning of the words used in s.739 the section applies only...
The Ramsay principle, as stated in Furniss v. Dawson [1984] STC 153, allows tax legislation to applied to the substance of a transaction. Steps inserted artificially with no...
Depreciatory transactions. Section 176 TCGA 1992 (formerly s.280 TA 1970).The machinery of section 176 (reduction of allowable loss on a disposal of shares in a company if the...
Rectification. Loan documentation: interest clause. Composite rate tax.Both parties to a contract were mistaken as to the tax regime which applied. Section 476(5) ICTA 1988. Crawley Borough Council...
Mr Sheppard is a stockbroker. In the late 1980’s he incurred legal costs of ¬¨¬£200,000 odd and had to pay a Stock Exchange fine of ¬¨¬£50,000. The costs...
Notices requiring a third party to produce documents, issued by the Inland Revenue during tax investigations. s.20(3) TMA 1970.The draft notices issued by the Revenue in this case...
Enterprise zones, Industrial Buildings Allowance. Section 21(1) CAA 1990.Where an enterprise zone building was purchased after first use, and the purchaser claimed industrial buildings allowance for the purchase...
