COMPENSATION PAYMENT for loss of office – Post Office Network Reinvention – whether capital payment for goodwill – or compensation for loss of office- payment compensation for loss of office – HMRC out of time to raise discovery assessment – section 29 (4) Taxes Management Act 1970 – appeal allowed [2011] UKFTT 707 (TC) Bailii … Continue reading Singh v Revenue and Customs: FTTTx 4 Nov 2011
INCOME TAX – discovery assessments – Taxes Management Act 1970 ss. 9A, 12B, 28A, 29, 34, 36 – onus of proof – whether discovery ‘stale’ – whether the condition under s 29(4) met for the ordinary time limit to be extended – income returned on an accruals basis – quantum of insufficiency varied for a … Continue reading Kantopoulos v Revenue and Customs No 2 (Income Tax – Discovery Assessments): FTTTx 19 Jul 2019
SCIT SHARE OPTIONS – unapproved scheme – gains by employee – whether charge to income tax arises when options exercised but shares not sold – yes – ICTA 1988 s 135(1). ASSESSMENT – power to raise assessment – whether loss of tax attributable to negligent conduct on the part of the Appellant or the person … Continue reading An Employee v Revenue and Customs: SCIT 19 Mar 2008
FTTTx CAPITAL GAINS TAX – Whether a ‘discovery’ – Whether conditions of either s 29(4) or (5) Taxes Management Act 1970 fulfilled – Yes – Appeal dismissed Citations: [2012] UKFTT 207 (TC) Links: Bailii Jurisdiction: England and Wales Capital Gains Tax Updated: 26 March 2022; Ref: scu.462588
FTTTx INCOME TAX – Further assessment to income tax on gain from exercise of share options – s 29 TMA 70 – whether discovery – yes – whether either of conditions in s 29(4) and (5) met – yes – income gain correctly calculated under Ch 5 Pt 7 ITEPA 2003 – yes – appeal … Continue reading Norman v Revenue and Customs: FTTTx 22 Jun 2015
UTTC CAPITAL GAINS TAX – validity of a ‘discovery’ assessment under section 29(1) of the Taxes Management Act 1970 – whether a ‘discovery’ – whether conditions of section 29(4) and (5) of the Act satisfied Newey J [2013] UKUT 623 (TCC), [2014] STC 915, [2014] STI 433, [2014] BTC 502 Bailii Taxes Management Act 1970 … Continue reading Sanderson v HM Revenue and Customs: UTTC 6 Dec 2013
References: [2013] UKUT 623 (TCC) Links: Bailii Coram: Newey J UTTC CAPITAL GAINS TAX – validity of a ‘discovery’ assessment under section 29(1) of the Taxes Management Act 1970 – whether a ‘discovery’ – whether conditions of section 29(4) and (5) of the Act satisfied Statutes: Taxes Management Act 1970
