Wills & Trusts Law Reports | January/February 2016 #156The appellants (CB and JB) brought an appeal against a decision of the First-tier Tribunal (FTT) on 25 June 2013 in which it dismissed the appellants’ appeals against closure notices by HMRC containing amendments to the appellants’ self-assessment tax returns for 2002-03. The effect of the amendments was that the appellants were liable to capital gains tax (CGT) of £849,644 and £317,417 respectively of additional gains under s87 of the Taxation of Chargeable Gains Act 1992 (TCGA) and supplemental charges under TCGA, s91.
In 1969, the ap...
Keith Dudley summarises the private client aspects of Sham Transactions The excellent introduction by the editors sets the scene and the following chapters 2-5 contain some fascinating and historical information and background. Some years ago Willoughby’s Misplaced Trust (second ed) by James Wadham was published by Gostick Hall Publications. As the title suggests, this book, …
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Wills & Trusts Law Reports | June 2012 #120James Albert McLaughlin (taxpayer), who was UK resident, engaged in a marketed planning scheme to avoid tax on a capital gain that he had made on the sale of a business. The scheme involved the acquisition by exchange of shares for overseas registered loan notes issued by two subsidiaries of Skandia UK Ltd (loan notes). The taxpayer then transferred the loan notes to SG Hambros Trust Company Ltd (trustee) to hold on the trusts of a settlor-interested settlement that he had established on 5 February 2003. By a deed of addition made a month later, the trustee added Adrian Gower, who was do...
