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Kahn and Another v Commissioners of Inland Revenue; In re Toshoku Finance plc: HL 20 Feb 2002

A company went into liquidation, being owed substantial sums by another company in the same group, but itself insolvent. A settlement did not include accrued interest, but was claimed to be taxed as if it had, and on an accruals basis. If so, was this an expense properly arising in the insolvency, and payable as … Continue reading Kahn and Another v Commissioners of Inland Revenue; In re Toshoku Finance plc: HL 20 Feb 2002

Acts

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Mark Buzzoni and Others v HM Revenue and Customs – FTC/57-59/2011; UTTC 19 Oct 2012

References: [2012] UKUT 360 (TCC) Links: Bailii UTTC Whether s. 102(1)(b) of the Finance Act 1986 (gift with reservation) applies to a gift of a reversionary underlease containing covenants from the donee mirroring covenants in the donor’s head lease. Application of Ingram v. IRC. Decision of the First-tier Tribunal upheld: such covenants do constitute a … Continue reading Mark Buzzoni and Others v HM Revenue and Customs – FTC/57-59/2011; UTTC 19 Oct 2012

Buzzoni and Others v Revenue and Customs, Re The Estate of Lia Kamhi (Deceased)): CA 19 Dec 2013

Moses, Black, Gloster LJJJ [2013] EWCA Civ 1684 Bailii Finance Act 1986 England and Wales Citing: At FTTTx – Buzzoni and Others v Revenue and Customs FTTTx 21-Apr-2011 FTTTx INHERITANCE TAX – grant of future underlease – covenants reserved – whether donor excluded or virtually excluded – appeal dismissed . . Appeal from – Buzzoni … Continue reading Buzzoni and Others v Revenue and Customs, Re The Estate of Lia Kamhi (Deceased)): CA 19 Dec 2013

Percy v Church of Scotland Board of National Mission: HL 15 Dec 2005

The claimant appealed after her claim for sex discrimination had failed. She had been dismissed from her position an associate minister of the church. The court had found that it had no jurisdiction, saying that her appointment was not an employment. However the jurisdiction in sex discrimination cases was wider, extending to those who ‘contract … Continue reading Percy v Church of Scotland Board of National Mission: HL 15 Dec 2005

Snook v London and West Riding Investments Ltd: CA 1967

Sham requires common intent to create other result The court considered a claim by a hire-purchase company for the return of a vehicle. The bailee said the agreement was a sham. Held: The word ‘sham’ should only be used to describe an act or document where the parties have a common intention that the act … Continue reading Snook v London and West Riding Investments Ltd: CA 1967