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JOHN TALLON QC assesses the CGT measures proposed in the 2005 Budget.
THE GENERAL RULE is that liability to UK CGT on chargeable gains accruing on the disposal of an asset only attaches to taxpayers who are either resident or ordinarily resident in the UK in the year of assessment in which the disposal is made ( TCGA 1992, s 2(1) ). That general rule is subject 'to any exceptions provided' by the TCGA.
Is it surprising that taxpayers feel resentful when the tax system contains such manifest unfairness, asks JOHN TALLON QC.
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Taxation readers comment on topical issues.
Is Anyone Out There Listening?
I write in support of John Tallon's article published in Taxation on 24 June 2004 .
He rightly cites Adam Smith's four maxims about taxation, which remain as true today as when they were written and from which this Government is departing, particularly with arbitrary tax changes and excessive complexity increasing the cost of administration and collection.
Is Anyone Out There Listening?
I write in support of John Tallon's article published in Taxation on 24 June 2004.
He rightly cites Adam Smith's four maxims about taxation, which remain as true today as when they were written and from which this Government is departing, particularly with arbitrary tax changes and excessive complexity increasing the cost of administration and collection.
JOHN TALLON QC enunciates his interpretation of the Court of Appeal's judgment
in Grimm v Newman.
AS ONE OF the counsel involved in the recent appeal to the Court of Appeal (its
decision now being final) of the decision of Mr Justice Etherton in Grimm v
Newman [2002] STC 1388, I read with interest the article of Malcolm Gunn, 'A
Fairytale Ending?', Taxation, 21 November 2002 at pages 177 to 180.
The article says that the Court of Appeal 'appeared to accept the proposition
