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PRIVATE CLIENT TAXES


HMRC has previously published two consultation documents setting out proposals on how the IHT treatment of relevant property trust charges could be simplified.

Assessing rental income

With the surprising decision handed down recently in Corbett, James Austen examines the facts and asks what planning opportunities, if any, the First-tier Tribunal decision could afford to other taxpayers who might qualify for entrepreneurs’ relief.

Finance Bill 2014 included proposed legislation for social investment tax relief, a relief available to investors in social enterprises from 6 April 2014. Tim Smith and Richard Wilson take a look.

HMRC has published draft guidance, for comment, for inclusion in a new authorised contractual scheme (ACS) manual. The guidance does not cover SDLT and capital allowances and HMRC warns that the guidance on CGT may be amended.

Jackie Wheaton answers a query on whether interest has a UK source, reviewing the key issues following Perrin v HMRC

The scheme involved ‘gifting’ gilts to a charity subject to option and security arrangements which ensured that 99% of the gilts would be passed on to a trust set up for the benefit of Mr Ferguson and his family.

IHT: transfer to personal pension fund

Income tax scheme failed

Andrew Goldstone and Victoria Howarth provide an update on recent developments affecting the taxation of private clients.

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