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Where Taxpayers and Advisers Meet

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by JSK TAXATION
Fri Oct 10, 2008 12:28 pm
Forum: Company Taxation
Topic: Loans
Replies: 3
Views: 958

<r>ML,<br/> <br/> Interseting question!<br/> <br/> A negligible value claim could be made by Company A under s24 TCGA 1992, but in my view this would be overidden by s18 of the same Act.<br/> <br/> S18 details the rules for transactions between connected parties. In the situation you put forwards ab...
by JSK TAXATION
Wed Oct 08, 2008 1:57 pm
Forum: Income Tax
Topic: Severance payments
Replies: 5
Views: 517

<r>R,<br/> <br/> Things are not as straight forwards as Peter is suggesting.<br/> <br/> Generally, a payment made on the termination of employment will be taxable as earnings where the employee is entitled to receive it under the terms of his contract. The contract may be express or implied.<br/> <b...
by JSK TAXATION
Wed Oct 08, 2008 1:42 pm
Forum: Capital Gains Tax, CGT
Topic: Value of company shares when transferring
Replies: 1
Views: 581

<r>craigthornton,<br/> <br/> Because it appears the transactions are between 'connected parties' for tax purposes they will be treated as being made at market value. Market value in this instance is unlikely to be calculated by simply dividing existing shareholders' funds by the number of issued sha...
by JSK TAXATION
Tue Oct 07, 2008 12:04 pm
Forum: Capital Gains Tax, CGT
Topic: Rebasing value of rented property
Replies: 4
Views: 808

<t>NoTaxEver,<br/> <br/> When you say total initial value, presumably you mean the value of the property at the later of:<br/> <br/> The date it was acquired (if acquired specifically to rent out) OR<br/> <br/> The date the property was appropriated to your property investment business (if used for ...
by JSK TAXATION
Tue Oct 07, 2008 9:36 am
Forum: Capital Gains Tax, CGT
Topic: Rebasing value of rented property
Replies: 4
Views: 808

<r>NoTaxEver<br/> <br/> I think you would need to be careful with this situation and I say this for the following reasons:<br/> <br/> If the property is sold from and back into your ownership then Stamp Duty Land Tax would be payable twice as would conveyancing fees. If the property is gifted, then ...
by JSK TAXATION
Mon Oct 06, 2008 7:58 am
Forum: Capital Gains Tax, CGT
Topic: Dubai first
Replies: 5
Views: 1293

<t>All contributors,<br/> <br/> tax me less is definitely getting his wires crossed! This issue would not need Counsel opinion.<br/> <br/> There are no mechanics for taxing a capital gain on UK situs assets for non residents unless they re-takeup residence within 5 tax years of leaving the UK in whi...
by JSK TAXATION
Sun Oct 05, 2008 8:26 am
Forum: Capital Gains Tax, CGT
Topic: Dubai first
Replies: 5
Views: 1293

<t>billyboy26,<br/> <br/> In order to avoid a CGT charge in the UK it will be necessary to sell the properties in a tax year following that in which you leave the UK.<br/> <br/> Providing you are then resident in a jurisdiction which either doesn't have a CGT regime (eg Dubai) or 'washes out' gains ...
by JSK TAXATION
Fri Oct 03, 2008 10:54 am
Forum: Property Taxation
Topic: CGT/equity release gifting property
Replies: 4
Views: 790

<t>jrkhany,<br/> <br/> Notwithstanding Lee's follow up to my post, I think it would be wise to deal with the tax issues now rather than wait for any problems to arise in the future. A simple letter to HMRC explaining the nature the arrangement should suffice to preclude any CGT having accrued by vir...
by JSK TAXATION
Fri Oct 03, 2008 10:25 am
Forum: General
Topic: Substantial Shareholding Exemption
Replies: 1
Views: 557

Jel117,

The holding company (i.e. the one claiming the exemption) must be UK resident, but the subsidiary need not.

Kind regards,

John S King
Chartered Tax Adviser
www.taxation-advice.com
by JSK TAXATION
Fri Oct 03, 2008 9:09 am
Forum: Property Taxation
Topic: CGT/equity release gifting property
Replies: 4
Views: 790

<r>jrkhany,<br/> <br/> Subject to the very limited information provided, and notwithstanding the nature of any formal documentation covering the arrangements, I think it very much arguable that a contructive trust exists.<br/> <br/> In this case, you are merely holding the property on trust for your...

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