Remittances from employment income
Could I be allowed to add a postscript to Peter Vaines' excellent and well-argued article (A Grimm Tale) in Taxation, 10 January 2002 at pages 321 to 323? This concerned the decision in Grimm v Newman [2001] STI 1406 and the gift of funds overseas to a wife to enable her to buy her half share in a jointly owned United Kingdom property.
Remittances from employment income
Could I be allowed to add a postscript to Peter Vaines' excellent and well-argued article (A Grimm Tale) in Taxation 10 January 2002 at pages 321 to 323? This concerned the decision in Grimm v Newman [2001] STI 1406 and the gift of funds overseas to a wife to enable her to buy her half share in a jointly owned United Kingdom property.
I completely agree with Peter's analysis as to the meaning of remittance as it applies for the purposes of Cases IV and V. But is it relevant to the Grimm case? Readers should be careful to bear in mind that different much wider rules will apply when considering the remittance of capital gains or of employment income (more careful perhaps than Mr Justice Etherton who seems at some points in his judgment to...
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