Of toothwort and trustees

Key points * HMRC manual says trustees can get capital treatment if TA 1988 s 219 applies to purchase. * 'Old' s 686A said trustees were always charged to income tax. * 'New' s 686A had to be amended. * Seems to import s 14 definition of qualifying distribution excluding those covered by s 219.

THERE I WAS quietly browsing HMRC's Trusts Settlements and Estates Manual as if I had nothing better to do when I happened upon paragraph TSEM3205. Perhaps I should explain; I did have better things to do. It was 30 March and I was heading for the Chartered Institute of Taxation Spring Conference; a chance to meet old friends and acquaintances hear some excellent lectures on recent developments and if I could find time prepare some slides for the Finance Bill presentations I was due to give....