It would be appropriate for the Revenue to allow the taxpayers’ claims for Jelley losses in certain cases, according to a department body for advising on tax dispute policy.
G Weston (TC3152)
R Dyer and J Dyer (TC3073)
UK resident clients have sold a property in Florida. Once depreciation has been added back, a capital gains arises in respect of the sale, but unrelieved losses are brought forward from letting the property. US tax law provides that losses from passive income can be seat against a gain on the sale of the asset
Resubmitted return was not relevant to calculation of tax
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?
HMRC have changed their minds about the implications of the decision in Mansworth v Jelley as far as the cost of shares is concerned, which has caused confusion about losses brought forward and the costs to be taken into account in future disposals
Land Securities plc v CRC, Upper Tribunal (Tax and Chancery Chamber)
The decision of whether or not to make an overseas capital loss election is not straightforward