Gedir v HMRC [2016] UKFTT 188 (TC)

Wills & Trusts Law Reports | June 2016 #160

In 2008, the appellant (A) was employed by Bear Stearns in the risk arbitrage unit before and during the period that it was acquired by JP Morgan. A received an offer from JP Morgan to continue to work in his role at the bank, which he accepted. But ultimately in September 2008, he took up a role with Goldman Sachs instead along with other members of his team at Bear Stearns. On leaving Goldman Sachs in 2010, A received a termination payment of £627,965 which he reported in his tax return.

A claimed foreign service relief on the termination payment. The ‘foreign service’ related t...

Litman & anr v HMRC [2014] UKFTT 089 (TC)

Wills & Trusts Law Reports | June 2015 #150

This was the conjoined appeal of two taxpayers against penalty determinations issued against them by HMRC. The taxpayers, who were both business people who held directorships in a number of UK companies, had realised capital gains on the disposal of an entity known as Efforsenrab Ltd and land and buildings in Essex in the UK. They participated in a capital redemption policy scheme and claimed a capital loss arising from that scheme to be set against the capital gains which they had realised. They both signed a professional services agreement with a tax adviser under which it agreed to pr...

Hanson v HMRCC [2012] UKFTT 314 (TC)

Wills & Trusts Law Reports | December 2012 #125

In 2006, the appellant received loan notes as part of the consideration for a sale of a business. He disposed of these loan notes in 2008. The disposal gave rise to a chargeable gain for Capital Gains Tax (CGT) purposes of £1,261,387. Following the disposal the appellant read an article which suggested that UK holiday letting properties could be used to mitigate CGT charges. The appellant had already purchased such a property. He consulted with his usual accountants, Clarke Broom Flemming (CBF) who indicated to the appellant that a form of holdover relief would be available to mitigate t...