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Capital Gains

Wade Llewellyn (TC02726)

A UK-domiciled and resident taxpayer has invested in bitcoins, the new online currency. A substantial gain was made on the sale of the bitcoin holdings, but how should this be treated for tax purposes?

Taxpayers who have kept silent about profit earned on the offloading of a residence other than their main homes have one month left to make use of an HMRC ‘amnesty’.

The property sales campaign is aimed at people who have made money on the sale of second homes in the UK or abroad – including those that have been rented out or used only for holidays – and have not paid the necessary capital gains tax (CGT).

The capital gains tax only or main residence exemption generally applies to only one residence. Advice is requested on the eligibility of a UK residence when married forces personnel and their families are living in married quarters in the UK or abroad. Does a formal election need to be made?

S and L McCaughern (TC2700)

How to obtain entrepreneur’s relief on liquidation

Shortly before the self-assessment tax return filing deadline, a client gave notification that a land transaction had taken place. A form CG34 was submitted, but HMRC are refusing to carry out a post-transaction valuation check

Three brothers own the shares in a trading company which trades from premises owned personally. They wish to dispose of the property and plan to each gift a 5% shareholding to their wife to enable the sale to be treated as an associated disposal

A payment may be made by the transferor of an asset to persuade the transferee to assume ownership. Does the decision in Aberdeen Construction Group Ltd mean it is possible for an acquisition cost to be a negative figure?

Ramsay v CRC, Upper Tribunal (Tax and Chancery Chamber)

An entrepreneurial client has built up an unquoted company. He now owns 100% of the share capital, having acquired other holdings from elderly relatives. Those transfers were subject to holdover elections, but if shares are transferred to his wife, will a gain crystalise?

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