CGT Archives - McKie & Co

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When does the period of ownership for private residence relief begin? This question was considered by the Upper Tribunal in HMRC v Lee

This issue of the Rudge Revenue Review examines the Upper Tribunal’s decision in HMRC v. Lee in which the previous decision of the FtT was confirmed in a judgment which…

The CGT consequences of typical transactions in respect of flat management companies can produce an unwelcome surprise

Such is the complexity of our tax system that it is unfortunately common for arrangements widely implemented by large numbers of taxpayers not to have the fiscal effects which they…

It must, surely, not be uncommon for buyers of residential properties substantially to reconstruct them or to demolish the existing building and to build a replacement residence. Yet the application…

How does CGT main residence relief apply where a house has been demolished and a new house built?

In three recent cases on the CGT treatment of lost deposits, Hardy, Lloyd-Webber and Drake, HMRC, in order to maximise its revenue, attempted to exploit, successfully in two of the…

The cases of Hardy, Lloyd-Webber and Drake reveal the asymmetric CGT effects of forfeited deposits and a more fundamental and long-stranding defect in the CGT legislation.

The case of Boston Khan v. HMRC [2021] calls into question the Courts’ even-handedness in applying basic principles of statutory construction where their effect is beneficial to the taxpayer.

This short article considers the 30-day reporting requirement for all direct disposals of UK land from the perspective of both the taxpayer himself and of the solicitor acting for him.

This issue discusses the importance to a taxpayer of making a detailed disclosure with his tax return to HMRC as to his residence and domicile status.

The main subject of this conference is domicile including the recently domiciled, long-term resident and formerly domiciled rules.

This lecture examines recent tax cases which are examples of ‘abusive tax collection’ by HMRC and which highlight HMRC’s unconscionable behaviour towards taxpayers.

This short article discusses HMRC’s change in its guidance following the CIOT’s representations based on the example in Simon McKie’s article Fair Administration?

This article considers HMRC’s restriction of relief given by Extra-statutory concession D33 for gains arising on the disposal of certain rights to take Court action