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PRIVATE CLIENT TAXES


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

Martin Mann provides guidance on the taxation of gift of shares in a family company

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

HMRC has published guidance on the lifetime allowance protections which are available to individuals who have pension savings worth more than the £1.25m lifetime allowance.

Entrepreneurs’ relief: was the vendor an employee?

Following the Autumn Statement announcement, the government is now consulting until 20 June 2014 on the proposals planned to take effect from April 2015, whereby non-residents disposing of UK residential property will be subject to a CGT charge.

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