Davis v Henderson (HMIT) and Pritchard v Purves (HMIT) – CGT – surrender of agricultural tenancy – capital sum received for surrender of rights under tenancy – compensation for disturbance paid after notice to quit followed by surrender – whether tenancy terminated by reason of, or in consequence of, notice to quit – whether statutory compensation – whether capital sum received from surrender of rights.
Holdings Ltd v Money (HMIT) – CGT – group of companies – non-cumulative redeemable preference shares issued by wholly owned subsidiary to parent – subsequent redemption of shares – whether reduction to nil of indexation allowance on redemption just and reasonable.
Jones v Wilcock (HMIT) – CGT – principal private residence exemption – loss on disposal – taxpayer sought to disapply exemption – whether residence acquired wholly or partly for purpose of realising a gain.
Plumbly and Others (personal representatives of the estate of Harbour (Dec’d) v Spencer (HMIT) – CGT – retirement relief – business owned by family company – land owned by taxpayer – leased to company – taxpayer sold land on reaching retirement age – business of company ceased – whether entitled to retirement relief on gain from land – whether relief confined to assets of the business – s 69(2)(b) FA 1985.
B’s Settlement – CGT – trusts – whether UK trust validly exported to become non-UK resident.
Figg v Clarke (HMIT) – CGT – settled property – beneficiary absolutely entitled to all assets comprising settled property – trustees revocably exercised power of appointment and appointed that investments be held in trust for issue of beneficiary as living or to be born who attained 21 years – beneficiary had four children at date of appointment – beneficiary later became physically incapable of further issue – trustees executed deed of release by which appointment became irrevocable – beneficiary died 14 years later – whether as a matter of law a person could become incapable of producing issue – whether beneficiary’s issue became absolutely entitled to settled property as against trustees at date of death of beneficiary or some earlier date – s 54(1) CGTA 1979.
Watton (HMIT) v Tippett – CGT – business assets – replacement relief – consideration of sale for old assets applied in acquisition of new assets – purchase of single property followed by sale of part – whether retained part could constitute new assets – s 115 CGTA 1979.
Garner (HMIT) v Pounds Shipowners and Shipbreakers Ltd – CGT – option to purchase land – consideration paid for option – consideration repayable in certain circumstances – grantor to use best endeavours to obtain release of restrictive covenants – grantor made payment to obtain release of restrictive covenants – whether consideration for grant of option chargeable without deduction of payment to obtain release of restrictive covenants – ss 32, 40(2) CGTA 1979.
Close Menu