I was pleased to speak recently at The Tax Journal's new Tax Practitioners' Group where I was asked why HMRC had changed its view on an aspect of the capital gains tax (CGT) treatment of employee share options and why we are treating taxpayers differently depending on whether their cases were open or closed.
By way of background when we lost the Mansworth v Jelley employee share option case in 2002 we published guidance in January 2003 to reflect our understanding of that decision. Our understanding at the time was that people could obtain a 'double deduction' for the amount charged to income tax on the option gain when calculating their CGT liability on the subsequent disposal...
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I was pleased to speak recently at The Tax Journal's new Tax Practitioners' Group where I was asked why HMRC had changed its view on an aspect of the capital gains tax (CGT) treatment of employee share options and why we are treating taxpayers differently depending on whether their cases were open or closed.
By way of background when we lost the Mansworth v Jelley employee share option case in 2002 we published guidance in January 2003 to reflect our understanding of that decision. Our understanding at the time was that people could obtain a 'double deduction' for the amount charged to income tax on the option gain when calculating their CGT liability on the subsequent disposal...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
