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Sink or swim?

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19 July 2011

Issue: 4313 / Categories: Forum & Feedback

Is it possible to avoid a capital gains tax liability in any country by, for example, entering into a transaction in mid-ocean?

Having read the answers to the query Lost property a thought that seems too good to be true occurred to me.

If the sale (i.e. the exchange of a non-conditional contract) of the property in question – the house in the USA – took place on board say a liner bringing the vendors from the USA back to the UK would they be regarded as not resident in either country with the gain therefore not liable to capital gains tax in either country?

I would be very interested in hearing readers’ views on this point. If there is a possible planning point here could it be used in any other situations?

Query 17 831 – Titanic

Reply from Tower

The earlier query concerned a UK property rather than a US property...

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Sink or swim?

© Copyright LexisNexis 2024. All rights reserved.

19 July 2011

Is it possible to avoid a capital gains tax liability in any country by, for example, entering into a transaction in mid-ocean?

Having read the answers to the query Lost property a thought that seems too good to be true occurred to me.

If the sale (i.e. the exchange of a non-conditional contract) of the property in question – the house in the USA – took place on board say a liner bringing the vendors from the USA back to the UK would they be regarded as not resident in either country with the gain therefore not liable to capital gains tax in either country?

I would be very interested in hearing readers’ views on this point. If there is a possible planning point here could it be used in any other situations?

Query 17 831 – Titanic

Reply from Tower

The earlier query concerned a UK property rather than a US property...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Subscribe Now...

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.

Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.

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4313

Categories: Forum & Feedback [1]

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