Perfect 10

X is a hard-working practising accountant who has built up a portfolio of investment properties. Some of the properties are owned entirely by her whereas others are held as part of consortia; the percentage ownership in each case is different as is the make-up of each consortium.

Last autumn X and the other relevant fellow members of one consortium decided to transfer that consortium’s one property from investment to trading stock.

The relevant capital gains tax election was made to effect the transfer at no gain/no loss but at 5 April 2009 the property was revalued to the lower of cost and net realisable value.

As a result the property has been written down and each consortium member will realise a loss on this property for 2008/09.

For X her share of the loss will be £50 000 and she wishes to offset this against other...