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MARK McLAUGHLIN explains why a company's 'trading company' status may depend on the HMRC official considering its Code of Practice 10 application.
IT IS UNFORTUNATE that there is very often a necessity for tax advisers to include phrases like 'it all depends …' and 'subject to …' in their advice to clients. I can imagine that many clients interpret such phrases as 'ifs' and 'buts' and ask themselves 'does he really know what he's talking about?'! I have to confess that when it comes to predicting how HMRC will react in certain situations the answer is 'probably not'!
MARK McLAUGHLIN CTA (Fellow), ATT, TEP, considers a problem with Code of Practice 10 taper relief rulings on trading company status, and offers a possible solution.
IT ALWAYS WORRIES me when HM Revenue & Customs (HMRC) announce a clarification of legislation. Past experience causes apprehension that the 'clarification' is going to leave me even more uncertain than before! A recent example of this is HMRC's guidance on the definition of 'trading company' for capital gains tax taper relief purposes and the measures to be applied when determining trading company status.
MARK MCLAUGHLIN considers some alternative methods of extracting value from family and owner-managed trading companies.
MARK McLAUGHLIN CTA (Fellow), ATT, TEP examines important recent changes affecting capital gains tax main residence relief.
THE SECOND ARTICLE of this series of two, looks at the changes to the operation of capital gains tax only or main residence relief made in the FA 2004 in response to what the Government perceived as unacceptable tax planning. (All references are to the Taxation of Chargeable Gains Act 1992, unless otherwise stated.)
MARK McLAUGHLIN CTA (Fellow), ATT, TEP examines important recent changes affecting capital gains tax holdover relief.
PARTS OF THE tax legislation remind me of my first car. The vehicle was fairly old, but it ran reasonably well on the whole. However, not having much money to spend in those days on car repairs and such like, it was often a case of 'patch up and make do'. Unfortunately, this strategy did not always work, and the repair bill often seemed out of proportion to the original breakdown.
