Share Disposals And Anti-Avoidance – Decisions, Decisions!
When an individual shareholder sells shares in a ‘close’ family or owner-managed trading company, he or she will probably expect the proceeds to be treated as a capital receipt. If the individual is liable to capital gains tax (CGT) on the share sale, in many cases the tax rate will be 20% (for 2018/19), although […]
Private Residence Relief: Tables Turned On HMRC!
Individuals who dispose of a dwelling house sometimes find themselves in disputes with HM Revenue and Customs (HMRC) over whether private residence relief (PRR) is due on the disposal of the property for capital gains tax (CGT) purposes (under TCGA 1992, s 222). Numerous cases have reached the courts and tribunal over the years. Burden […]
Incorporation: A Borrowing Trap
Many landlords introduce properties into their rental businesses, which may have already been held for some time (e.g. gifted or inherited property). Those landlords are, in effect, introducing capital into the business, broadly equal to the market value of the property when it was introduced, less any outstanding mortgage, etc. Allowable borrowings HM Revenue and […]
Incorporation: A Borrowing Trap
Many landlords introduce properties into their rental businesses, which may have already been held for some time (e.g. gifted or inherited property). Those landlords are, in effect, introducing capital into the business, broadly equal to the market value of the property when it was introduced, less any outstanding mortgage, etc. Allowable borrowings HM Revenue and […]
Private Residence Relief: Another Disappointed Taxpayer
Private residence relief (PRR) for capital gains tax (CGT) purposes is potentially very generous. For example, a UK resident individual who is a higher rate taxpayer is liable to CGT on a residential property gain at 28% (for 2017/18). However, if PPR is available in full, the individual’s gain on disposal is not a chargeable […]
Private Residence Relief: Another Disappointed Taxpayer
Private residence relief (PRR) for capital gains tax (CGT) purposes is potentially very generous. For example, a UK resident individual who is a higher rate taxpayer is liable to CGT on a residential property gain at 28% (for 2017/18). However, if PPR is available in full, the individual’s gain on disposal is not a chargeable […]