Jointly held property: whether appellant a settlor
In PA Lorber v HMRC (No 1) (TC00977 – 1 March) a married couple held joint bank accounts on which interest arose. The husband (L) failed to declare any of this interest on his tax returns. HMRC issued amendments to his self-assessments and discovery assessments for previous years on the basis that L was taxable on 50% of this income. L appealed contending that the interest should be treated as belonging solely to his wife. The First-tier Tribunal rejected this contention and dismissed his appeal observing that L and his wife could have made a declaration of unequal beneficial interests under what is now ITA 2007 s 837 but had failed to do so.
In the same case L’s two young children received income from several building societies. HMRC issued assessments on L on the...
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Jointly held property: whether appellant a settlor
In PA Lorber v HMRC (No 1) (TC00977 – 1 March) a married couple held joint bank accounts on which interest arose. The husband (L) failed to declare any of this interest on his tax returns. HMRC issued amendments to his self-assessments and discovery assessments for previous years on the basis that L was taxable on 50% of this income. L appealed contending that the interest should be treated as belonging solely to his wife. The First-tier Tribunal rejected this contention and dismissed his appeal observing that L and his wife could have made a declaration of unequal beneficial interests under what is now ITA 2007 s 837 but had failed to do so.
In the same case L’s two young children received income from several building societies. HMRC issued assessments on L on the...
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