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Capital Gains Tax: A question of interpretation
Alex Tamosius explains the implications of Foulser v HMRC [2015] ‘The difference of opinion between the Foulsers and HMRC on the question of valuation is striking, but it is worth pausing from the tribunal’s answer to consider the more obvious question – why has it taken eight years from the Court of Appeal’s decision in …
Cases Referenced
Cases in bold have further reading - click to view related articles.
- Attorney-General of Ceylon v Mackie [1952] 2 All ER
- Duke of Buccleuch v CIR [1967] 1 AC 506
- Findlay's Trustees v IRC [1938] ATC 437
- Foulser & anor v MacDougall (Inspector of Taxes) [2005] EWHC 2958
- Foulser v HMRC [2015] UKFTT 220 (TC); WTLR(w) 2013-01
- Hardy v Motor Insurers Bureau (1964) 2 QB 745
- IRC v Clay [1914] 3 KB 466
- Lynall v IRC [1972] AC 680
- Re Holt [1953] 32 ATC 402