Andrew Goldstone and Stuart Adams (Mishcon de Reya) provide your monthly update.
Reeves: applying the rules of statutory interpretation
In W Reeves v HMRC [2018] UKUT 293 Mr Reeves (R) appealed to the UT after the FTT had denied his claim for holdover relief under the TCGA 1992 s 165.
Until 2007 R was resident and ordinarily resident in the UK but in 2007 he moved back to the US. Thereafter R and his wife and children were not resident or ordinarily resident in the UK.
His claim related to in 2010 of his interest in a trading partnership (the LLP) which operated a UK-based private hedge fund to a UK resident company (the company) of which he was the sole director and shareholder. The gift constituted disposal (the disposal) on account of TCGA 1992 s 10 which provides that a gain arising on the...
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Andrew Goldstone and Stuart Adams (Mishcon de Reya) provide your monthly update.
Reeves: applying the rules of statutory interpretation
In W Reeves v HMRC [2018] UKUT 293 Mr Reeves (R) appealed to the UT after the FTT had denied his claim for holdover relief under the TCGA 1992 s 165.
Until 2007 R was resident and ordinarily resident in the UK but in 2007 he moved back to the US. Thereafter R and his wife and children were not resident or ordinarily resident in the UK.
His claim related to in 2010 of his interest in a trading partnership (the LLP) which operated a UK-based private hedge fund to a UK resident company (the company) of which he was the sole director and shareholder. The gift constituted disposal (the disposal) on account of TCGA 1992 s 10 which provides that a gain arising on the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
