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Identifiying a person's only or main residence for capital gains tax purposes
MALCOLM GUNN FTII, TEP of Haarmann Hemmelrath discusses the impact of the pre-owned assets charge on three cases.
GORDON BROWN'S VISIT to Africa some while ago to announce his charitable efforts on behalf of that continent made headline news at the time, and rightly so. Those in Government have a clear duty to show sensitivity and compassion for all those upon whose lives their actions may have an impact, and to proceed in a spirit of reasonableness and respect for their fellow citizens.
MALCOLM GUNN FTII, TEP examines a controversial Revenue statement on termination payments.
IN 1991, THE Revenue issued a statement of practice which was part of its 'Mystifying Misinterpretations' series for practitioners. As readers may know, there is a companion set of publications, the 'Catastrophic Climbdowns' series, which is much smaller and includes the Revenue statement following the decision in Mansworth v Jelley [2003] STC 53, and another one from some years ago concerning insurance commission rebates.
Comment
Double Trouble
MALCOLM GUNN FTII, TEP discusses the conflicting tax requirements of purchaser and vendor on the sale of a fledgling company.
Readers' Forum
Loose Ends
Readers' planning points, pitfalls and other correspondence.
Sharkey v Wernher
In 'Sharkey Revisited', in Taxation, 24 July 2003 at pages 443 to 446, I set out reasons why I felt that the decision in Sharkey v Wernher 36 TC 275 could be challenged, either as always having been wrong or at least having been obsolete since the introduction of section 42, Finance Act 1998.
