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Where Taxpayers and Advisers Meet

Search found 96 matches

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by simpsonite
Mon Jun 19, 2017 12:08 pm
Forum: Capital Gains Tax, CGT
Topic: Hope value
Replies: 2
Views: 569

Hope value

Hi All, My client bought a plot of land back in 89/90 for £30k. He had planning permission and built his own personal residence on 2/3rds of the land purchased. It appears that he did not have planning permission to build on the remaining 1/3rd. However, in 06 planning permission was granted and he ...
by simpsonite
Fri Jan 06, 2017 12:24 pm
Forum: Capital Gains Tax, CGT
Topic: Furnished Holiday Letting & Let relief for CGT
Replies: 3
Views: 841

Re: Furnished Holiday Letting & Let relief for CGT

Thanks for that bd6759.

Owen V Elliot (1990) completely slipped my mind ;)

A FHL is going to be residential as would a guest house for short term letting purposes.
by simpsonite
Thu Jan 05, 2017 12:09 pm
Forum: Capital Gains Tax, CGT
Topic: Furnished Holiday Letting & Let relief for CGT
Replies: 3
Views: 841

Furnished Holiday Letting & Let relief for CGT

Hi all, My client lived in his main residence for six years , he then moved out and converted the property into a Furnished Holiday Let. It was been let out as such ever since prior to sale in 15/16. In addition to PPR relief. would my client also be entitled to let relief? Let relief would normally...
by simpsonite
Fri Oct 21, 2016 3:46 pm
Forum: Income Tax
Topic: Emoluments exempt from income tax received from United Nations
Replies: 1
Views: 1781

Emoluments exempt from income tax received from United Nations

Hi All, I am aware that there is an exemption from income tax in respect of emoluments received by individuals as officers of the United Nations. My query is whether the same exemption might apply for a self employed individual supplying exactly the same services as an officer of the United Nations?...
by simpsonite
Wed Aug 03, 2016 12:17 pm
Forum: Tax Investigations and Enquiries
Topic: Failure to notify Sch 41 Finance act 2008
Replies: 1
Views: 1595

Failure to notify Sch 41 Finance act 2008

Hi All, My client has an ongoing investigation into 6 tax years to 2014 that were not submitted. I have now completed the 6 years in question & HMRC have agreed the tax liability for the two years to 2014. The enquiry regarding the earlier 4 years will commence as soon as I agree or not the penalty ...
by simpsonite
Tue Feb 23, 2016 12:15 pm
Forum: Property Taxation
Topic: Acquisition at probate & property developer trading
Replies: 6
Views: 913

Re: Acquisition at probate & property developer trading

Yep thanks for that. One final point. If he decides to just obtain planning permission and sell the plot as it stands (house & large garden). Say he doesn't live there then a gain will arise based on sale proceeds less probate value (with an element of hope value attached) My query is whether HMRC w...
by simpsonite
Mon Feb 22, 2016 5:51 pm
Forum: Property Taxation
Topic: Acquisition at probate & property developer trading
Replies: 6
Views: 913

Re: Acquisition at probate & property developer trading

It appears its based at m.v at time he becomes a property developer under the Sharkey V Wherner principal.
A gain is crystalised at that point is my understanding & the plot would be appropriated to trading stock at that time.
by simpsonite
Mon Feb 22, 2016 5:08 pm
Forum: Property Taxation
Topic: Acquisition at probate & property developer trading
Replies: 6
Views: 913

Re: Acquisition at probate & property developer trading

Hi Maths, Yep I concur with your points. What about the market value of the land to be introduced into the property building business. Is it the mv of the levelled site with planning permission which is valued at over £1 million. Or is it the lower probate value of the plot (current house and garden...
by simpsonite
Mon Feb 22, 2016 3:52 pm
Forum: Property Taxation
Topic: Acquisition at probate & property developer trading
Replies: 6
Views: 913

Acquisition at probate & property developer trading

Hi All, My client has acquired his late father's home at probate. He is currently residing at the property. In the next few years he is looking to develop the plot and either sell it as it is with planning permission to a property developer or demolish the site & self build 4 new homes. The base cos...
by simpsonite
Mon Jun 08, 2015 9:39 am
Forum: Company Taxation
Topic: Dividend waiver & section 620 ITTOIA
Replies: 6
Views: 1596

Re: Dividend waiver & section 620 ITTOIA

bd6759, The extra 499 shares were issued to Mr on advice of prior accountant. As already stated earlier, it is my understanding that Mr was trying to protect his share of the company In the event of him & his wife splitting up. But in doing so it would appear that the divs should also have been spli...

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