ITTOIA 2005 and unambiguous provisions
Peter Halford (PwC Legal) reviews the decision in Trigg v HMRC, where the FTT held that euro redenomination clauses did not deprive bonds of QCB status.
Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments in the private client arena: the public register of corporate ownership; the tax liability of a John Constable painting acquired by the nation; the outcome of a transferable IHT nil rate band charity appeal; and lessons from a main residence exemption claim.
The Charity Tax Group (CTG) welcomes the publication of HMRC-commissioned research on understanding donor behaviour in relation to gift aid.
Mark Middleditch (Allen & Overy) provides an update of recent developments, including: the announcement of new rules on hybrid mismatches; the high-risk promoters regulations; euro conversion clauses; FATCA; and the EC investigation into the Irish tax rulings over Apple
Are bonds which may be redenominated in euros QCBs?
Lisa Stevenson (Parisi Tax) answers a query on tax-efficient investment in a start-up company.
Andrew Goldstone and Stuart Crippin (Mishcon de Reya) give an update on recent developments, including: Spanish inheritance tax refunds, pensions changes, and the cases of Hirst and Drown and another (as executors of Leadley deceased).
Effect of IHTA 1984 s 8A election on legacies
Definition of ‘convertible securities’