Where Taxpayers and Advisers Meet

Search found 6909 matches

Go to advanced search

by maths
Sat Oct 21, 2017 10:20 pm
Forum: Inheritance Tax, IHT, Trusts & Estates, Capital Taxes
Topic: Transactions during administration of an estate
Replies: 2
Views: 1280

Re: Transactions during administration of an estate

If sales price has been substituted for probate value then the sales price also becomes the acquisition price for CGT purposes. In such a case a small capital loss will arise on sale due to costs of disposal.

Sales by executors during the administration are subject to CGT (ie are not exempt).
by maths
Sat Oct 21, 2017 3:00 pm
Forum: International Tax
Topic: SA109 Split Year Type and Date Question
Replies: 5
Views: 1873

Re: SA109 Split Year Type and Date Question

The "significant break" test would apply if you ended your contract in say February 2018 and between that date and 5 April 2018 you failed to work for more than 3 hours overseas per day for 31 successive days (ignoring sickness; annual leave etc).
by maths
Sat Oct 21, 2017 2:54 pm
Forum: International Tax
Topic: SA109 Split Year Type and Date Question
Replies: 5
Views: 1873

Re: SA109 Split Year Type and Date Question

I assume this question is asking if I met the criteria in the 2016-17 tax year?


Correct. So your answer is that you do not satisfy it for 16/17.
by maths
Fri Oct 20, 2017 4:53 pm
Forum: International Tax
Topic: SA109 Split Year Type and Date Question
Replies: 5
Views: 1873

Re: SA109 Split Year Type and Date Question

Case 1 has priority.

First day of split year under Case 1 is 3 January 2017.

Last day is 2 January 2017.

Hence you will be resident up to and including 2 January 2017.

Case 1 also requires that the 3rd automatic overseas test is satisfied for tax year 2017/18.
by maths
Thu Oct 19, 2017 9:35 pm
Forum: International Tax
Topic: Offshore loan - mixed fund impact
Replies: 4
Views: 3503

Re: Offshore loan - mixed fund impact

am I now left with 14 of CG, 29 of RFI and 57 of clean capital having used 11 of CG, 21 of RFI and 43 of capital to settle the loan out of the pre-settlement balance of 25 CG, 50 RFI and 100 capital? Out of pre-settlement balance (as you say) of 25CG; 50 RFI; and 100 capital you then use: 100/175 t...
by maths
Thu Oct 19, 2017 8:32 pm
Forum: Income Tax
Topic: Foreign tax set against UK income
Replies: 4
Views: 3968

Re: Foreign tax set against UK income

The foreign tax credit position cannot be determined until a classification of the royalty income has been made.

Such income can arise from a trade/profession/vocation or it can constitute annual payment royalties (ie purely passive investment) or non-annual payment royalties (ITTOIA 2005 s579).
by maths
Thu Oct 19, 2017 8:17 pm
Forum: International Tax
Topic: Offshore loan - mixed fund impact
Replies: 4
Views: 3503

Re: Offshore loan - mixed fund impact

The loan proceeds receipt constitute "clean capital" [s809Q(4)]. Application of loan proceeds constitutes an "offshore transfer" [s809R(5)] thus proportion of each kind of income/gains/capital apply [s809R(4)]. Assumes, as appears to be be the case, that no part of mixed fund is ...
by maths
Wed Oct 18, 2017 2:38 pm
Forum: Inheritance Tax, IHT, Trusts & Estates, Capital Taxes
Topic: Immediate post death interests trusts & IHT 205
Replies: 3
Views: 5118

Re: Immediate post death interests trusts & IHT 205

Currently no trusts are involved. On the death of the first spouse to die a will trust (ie a will set up under a will) comes into being. Under that trust the deceased spouse's 50% interest in their home becomes settled in trust for the benefit of the surviving spouse. Thus, on the first death the de...
by maths
Wed Oct 18, 2017 1:52 pm
Forum: Property Taxation
Topic: Transferring rental income to my wife
Replies: 3
Views: 1803

Re: Transferring rental income to my wife

At the moment you have residence relief and lettings relief to offet against any future capital gain. Your wife may not be entitled to these, so they will be lost if you give the the proeprty to her. This may be surmountable by transferring less than 100% of the beneficial interest to wife and then...
by maths
Wed Oct 18, 2017 1:46 pm
Forum: Income Tax
Topic: Tax Rebate - Exchange Rate Help
Replies: 3
Views: 2195

Re: Tax Rebate - Exchange Rate Help

I assume this relates to foreign tax credit relief?

If so, the tax rebate in euros should be translated into £ at the time the income was earned not when repaid.

Go to advanced search