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Where Taxpayers and Advisers Meet

Search found 337 matches

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by Feedback
Tue Nov 26, 2019 1:42 pm
Forum: Capital Gains Tax, CGT
Topic: CGT on main residence land disposed of for development
Replies: 1
Views: 332

CGT on main residence land disposed of for development

a taxpayer has lived in his main residence for 20 years and has now acquired a piece of land (AB) adjacent to the main residence (CD). Lets say both pieces of land go from east to west, and are called AB and CD. the taxpayer wishes to split both pieces of land so that his 2 land parcels now run nort...
by Feedback
Fri Feb 01, 2019 3:44 pm
Forum: Company Taxation
Topic: s455 corp tax
Replies: 1
Views: 6231

s455 corp tax

if a company issues a loan to a director at a commercial rate, and the loan is repaid in monthly instalments, just like any other commercial loan, does this come under s455? per s456, the business is not a finance house, and the director owns 5% of equity.

my first thought is that it does
by Feedback
Wed Oct 10, 2018 3:03 pm
Forum: Capital Gains Tax, CGT
Topic: Land and ER
Replies: 10
Views: 986

Re: Land and ER

Thanks, that makes sense so if there are two brothers, one who owns land, and one who owns a trading company, which he is planning on selling. the trading company leased the land from the first brother. ER is available to the second brother and not the first (assumption here is that qualifying condi...
by Feedback
Tue Oct 09, 2018 7:48 pm
Forum: Capital Gains Tax, CGT
Topic: Land and ER
Replies: 10
Views: 986

Re: Land and ER

My bad, I'm aware of what tcga92 is, I just can't find s196h when I use legislation.gov.uk
by Feedback
Mon Oct 08, 2018 3:27 pm
Forum: Capital Gains Tax, CGT
Topic: Land and ER
Replies: 10
Views: 986

Re: Land and ER

what do you mean when you refer to S196H?
by Feedback
Mon Oct 08, 2018 1:20 pm
Forum: Capital Gains Tax, CGT
Topic: Land and ER
Replies: 10
Views: 986

Re: Land and ER

What if the landlord owns the 2 companies (or is a significant shareholder in each company) who leased the land, and used the land as trading asset rather than investment per the manual...

https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg64060

Does that change matters?
by Feedback
Mon Oct 08, 2018 1:09 pm
Forum: Capital Gains Tax, CGT
Topic: Land and ER
Replies: 10
Views: 986

Land and ER

Generally speaking, is land a qualifying business asset for the purposes of cgt? I've reviewed hmrc's cgt manual and it references farmland for development but not land in general. The background is a landowner acquired the commercial land, and has leased it to 2 separate companies over the years an...
by Feedback
Sat Aug 25, 2018 8:00 am
Forum: Capital Gains Tax, CGT
Topic: CGT, ER and property development/investment
Replies: 3
Views: 480

Re: CGT, ER and property development/investment

The property will be sold, its whether it should be treated as stock or investment.

The intention was to trade it as stock but market conditions have resulted in it being held as investment.
by Feedback
Fri Aug 24, 2018 1:52 pm
Forum: Capital Gains Tax, CGT
Topic: CGT, ER and property development/investment
Replies: 3
Views: 480

CGT, ER and property development/investment

where a group of individuals have set up a company with the intention to develop property, but given local market conditions are unable to sell the properties, and instead have temporarily rented the properties until conditions for sale are correct, would the winding up of a company via MVL be allow...
by Feedback
Fri Aug 10, 2018 8:57 am
Forum: Stamp Duty, Stamp Duty Land Tax, SDLT
Topic: FA03 s65
Replies: 0
Views: 709

FA03 s65

If a partnership own a piece of land (£9m value), and they wish to take on another partner (a limco) who is investing £2m development capital, this new partner insists on incorporating a LLP. Will s65 apply if the land is transferred to the LLP given the original partners interest will be diluted po...

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