In responding to HMRC’s plans to extend CGT to non-residents in certain circumstances, the Chartered Institute of Taxation (CIOT) has voiced concern over the proposed withdrawal of the principal residence election for all taxpayers.
Peter Stevens summarises the government’s proposals for charging tax on capital gains made by non-residents from disposals of UK residential property
Peter Vaines comments on the operation of CGT on non-residents and ATED
Andrew Goldstone and Victoria Turner review recent developments in the private client sphere
Paul Davison considers HMRC v The Executors of Lord Howard of Henderskelfe (deceased) on why a gain made on the disposal of an iconic painting should be exempt from CGT
Stephen Smith sets out the practical lessons from the Paul Daniel case concerning a taxpayer who realised a substantial capital gain whilst purporting to be working full-time abroad
EIS and taper relief
In Essack, the FTT decided that a payment to surrender a share option fell within ITEPA 2003 s 401 because it arose on the termination of employment. This seems at odds with HMRC’s guidance and another tribunal decision, writes Nigel Doran.
John Endacott discusses issues arising from the consultation document on CGT and non-residents