Capital Gains

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A marriage contract trust was made in 1947, with an alimentary liferent in favour of the wife. The couple would like to transfer the trust assets to their children

A company director purchased shares in his company that were subject to enterprise investment scheme relief and has also made loans. The director would like to purchase the business from the company, perhaps on a winding up, but is concerned that EIS relief might be clawed back

GARY HEYNES and SARAH TURGOOSE warn of the UK tax effect of currency exchange movements

Summary of Revenue & Customs Brief 16/09

REBECCA CAVE considers the interaction of capital losses and entrepreneurs’ relief

A taxpayer used a shared appreciation mortgage, secured on her main residence to purchase a buy to let property. Can any tax relief be obtained on the amount repaid either for capital gains tax or income tax purposes?

CHRIS HART explains the current state of play concerning the valuation of goodwill for SDLT and capital gains tax purposes

Summary of Revenue & Customs Brief 9/09

DAVID BOWES considers the Court of Session’s finding in Gray’s Timber Products Limited v HMRC that personal rights are ignored when valuing company shares

CRC v Collins, Chancery Division, 20 February 2009

Underwood v CRC, Court of Appeal, 15 December 2008

HMRC have given a clearance for the reconstruction of a holding company and its two subsidiaries into two separate companies. The clearance states that it does not extend to a sale or liquidation of the new companies. What are the implications?

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