Bed and Breakfasting Rule: If you sell and repurchase the same cryptocurrency within 30 days, the cost basis is the value of the assets purchased within that period. If the quantity sold exceeds the quantity repurchased, move to the final rule. Section 104 Rule: When the previous rules don...
HMRC did not serve its bundle of authorities until after 7pm on 17 June and it was accepted that Rule 12 of the Tribunal Rules required service by 5pm on the relevant date and, as such, HMRC were in breach of the directions and subject to the terms of the unless or...
Basis period changes A framework to combat identity fraud Unlock your practice potential roadshows Elite Business Live returning in March Warning over ‘failure to prevent fraud’ New guidance for employers on holiday rules Revised statutory code on flexible working requests Government publishes draft...
“HMRC recognised this and in 2013 introduced disincorporation relief for small businesses. Essentially, it is a simplification of the rules allowing limited companies to look at their options and, if appropriate, return to or change to unincorporated status in a tax efficient manner. “For many ...
In this scenario, you open up some interesting taxation rules. Your premiums will NOT be tax-deductible as the policy fails the wholly and exclusively test yet again. Here, your business is not the one benefiting from a payout; it’ll be the lender that’s the key beneficiary. ...
behaviour, the current time limit of 20 years will remain. The new legislation will not apply retrospectively but will apply to any case that is still in date for assessment when the new legislation comes into effect. The requirement to correct (RTC) rules have already extended the time ...
S18 ITEPA 2003 determines that the liability arises at the earliest of entitlement or payment (forgetting for the purposes of this exercise the separate rules for directors). So a payment of earnings that the taxpayer becomes entitled to prior to their death, but which is paid after their ...
Where the rules apply, the payment by the transferring partner is taxed as if it were partnership profit. Commentary The proposals have been a long time coming as HMRC announced some time ago its view that LLPs have been used to implement aggressive tax planning (sometimes poorly), and this...