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Where Taxpayers and Advisers Meet

Search found 99 matches

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by Brightonian
Mon Nov 07, 2011 3:41 pm
Forum: Capital Gains Tax, CGT
Topic: PPR extended relief
Replies: 21
Views: 2968

PPR extended relief

I have an interesting situation. My clients are husband and wife. H has let out for years a property which was once his PPR and was in his sole name. He was thinking of selling so I suggested that he transfer a 50% share to W before sale. He did this in March 2010 and continued to let the property o...
by Brightonian
Fri Aug 19, 2011 2:07 pm
Forum: International Tax
Topic: Maturing German life insurance policy
Replies: 2
Views: 1111

Re: Maturing German life insurance policy

Thank you. I was a little surprised that HMRC would want to include holidays etc. But it was an employee of a company taht markets offshore bonds wjo mentioned this to em and that makde me wonder. Thanky ou for the reassurance.
by Brightonian
Fri Aug 19, 2011 2:04 pm
Forum: Capital Gains Tax, CGT
Topic: Entrepreneurs' Relief - private equity limited partner
Replies: 2
Views: 966

Re: Entrepreneurs' Relief - private equity limited partner

Thank you, Maths. I suspected that would be the case.
by Brightonian
Fri Aug 19, 2011 2:03 pm
Forum: Capital Gains Tax, CGT
Topic: Mistake crystalising gain
Replies: 2
Views: 763

Re: Mistake crystalising gain

Hi, I feel for you - I've done this myself! If the disposal had been less than 30 days ago, you could have repurchased the same funds and the bed and breakfasting rules would have applied. If the client has a holding standing at a loss, you could crystallise a loss to match the gain. Of course, you ...
by Brightonian
Fri Aug 19, 2011 12:24 pm
Forum: Capital Gains Tax, CGT
Topic: Entrepreneurs' Relief - private equity limited partner
Replies: 2
Views: 966

Entrepreneurs' Relief - private equity limited partner

I have been asked if Entrepreneurs' Relief is available to a limited partner in a private equity fund based offshore - he is UK resident and domiciled. From what I've been able to find out, a limited partner is just another name for an investor. He will receive a distribution of which 30% is return ...
by Brightonian
Fri Aug 19, 2011 12:19 pm
Forum: International Tax
Topic: Maturing German life insurance policy
Replies: 2
Views: 1111

Maturing German life insurance policy

My client, a German national now resident in the UK, took out one of these policies 12 years ago and it will mature shortly. It is a 'capital life insurance' and appears to be similar to an endowment policy. There will be a gain on the policy. The proceeds are atxfree in Germany. I have researched t...
by Brightonian
Thu Feb 24, 2011 3:59 pm
Forum: Capital Gains Tax, CGT
Topic: S 48 TCGA 1992 claim - time limits
Replies: 8
Views: 4871

S 48 TCGA 1992 claim - time limits

My client sold his company in 2005/06 for a mixture of cash and loan notes. Clearances were obtained and only the cash was taxed in that year. there was also contingent ascertainable consideration in the form of further loan notes and shares in the new company. The loan notes were redeemed in 2009/1...
by Brightonian
Thu Feb 03, 2011 5:29 pm
Forum: International Tax
Topic: Share scheme and residence
Replies: 2
Views: 888

Re: Share scheme and residence

Thank you for replying. You have confirmed what I thought from the research I was able to do before the end of January but I am aware that this is a very complex area. The employers provided very little information. Thank you for your help-.
by Brightonian
Mon Jan 31, 2011 7:14 pm
Forum: International Tax
Topic: Share scheme and residence
Replies: 2
Views: 888

Share scheme and residence

My client is a member of an unapproved share plan. When she was R/OR she was awarded shares in her company. She is now not resident and the shares have vested and the employer has deducted tax at vesting. The shares vest over three years. There are no conditions attached. Is she taxable int he UK gi...
by Brightonian
Mon Jan 31, 2011 6:32 pm
Forum: International Tax
Topic: Share scheme and residence
Replies: 0
Views: 450

Share scheme and residence

My client is a member of an unapproved share plan. When she was R/OR she was awarded shares in her company. She is now not resident and the shares have vested and the employer has deducted tax at vesting. The shares vest over three years. There are no conditions attached. Is she taxable int he UK gi...

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