In A and T Hancock v HMRC [2017] EWCA Civ 198 (25 May 2017) the Court of Appeal found that a scheme intended to operate as a reorganisation within the scope of TCGA 1992 ss 126 to 130 should be treated as two separate conversions so that the gain did not disappear ‘in a puff of smoke’.
Mr and Mrs Hancock had sold the entire share capital of their company Blubeckers Ltd to another company and the consideration had consisted in loan notes issued by the purchasing company. The loan notes provided for a repayment in US dollars at an exchange rate other than the one prevailing at the date of redemption. They were therefore...
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In A and T Hancock v HMRC [2017] EWCA Civ 198 (25 May 2017) the Court of Appeal found that a scheme intended to operate as a reorganisation within the scope of TCGA 1992 ss 126 to 130 should be treated as two separate conversions so that the gain did not disappear ‘in a puff of smoke’.
Mr and Mrs Hancock had sold the entire share capital of their company Blubeckers Ltd to another company and the consideration had consisted in loan notes issued by the purchasing company. The loan notes provided for a repayment in US dollars at an exchange rate other than the one prevailing at the date of redemption. They were therefore...
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