Andrew Goldstone and Katie Doyle (Mishcon de Reya) review the latest tax developments affecting private clients.
O’Donnell: whether deductible cost of disposal
In J O’Donnell v HMRC [2017] UKFTT 347 (reported in Tax Journal 2 June 2017) the First-tier Tribunal (FTT) considered whether costs initially incurred by the purchaser but subsequently reimbursed by the seller on the sale of a property were deductible as incidental costs of disposal under TCGA 1992 s 38(1)(c) when calculating the seller’s chargeable gains on disposal.
The taxpayer had funded the purchase of three properties by way of a loan from Singer and Friedlander (before its takeover by Kleinwort Benson) which was secured over four properties in his portfolio. The terms of the loan were unusual: while the loan itself was drawn down in sterling the liability could be converted into different currencies at the lender’s discretion. Exchange rates...
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Andrew Goldstone and Katie Doyle (Mishcon de Reya) review the latest tax developments affecting private clients.
O’Donnell: whether deductible cost of disposal
In J O’Donnell v HMRC [2017] UKFTT 347 (reported in Tax Journal 2 June 2017) the First-tier Tribunal (FTT) considered whether costs initially incurred by the purchaser but subsequently reimbursed by the seller on the sale of a property were deductible as incidental costs of disposal under TCGA 1992 s 38(1)(c) when calculating the seller’s chargeable gains on disposal.
The taxpayer had funded the purchase of three properties by way of a loan from Singer and Friedlander (before its takeover by Kleinwort Benson) which was secured over four properties in his portfolio. The terms of the loan were unusual: while the loan itself was drawn down in sterling the liability could be converted into different currencies at the lender’s discretion. Exchange rates...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
