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Capital gains tax – Disposal of assets. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) allowed the appeal by the Revenue and Customs Commissioners against a decision of the First-tier Tribunal (Tax Chamber) to the effect that a disposal of cash by the taxpayers of two loan notes did not bring into charge an accrued capital gain. The tribunal decided that the effect of the conversion of those loan notes fell to be treated as one conversion to which s 116(1) of the Taxation of Chargeable Gains Act 1992 applied so that on the conversion of the successor notes, the frozen gain was realised under s 116(10) of that Act.
Capital gains tax – Disposal of assets. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) allowed the appeal by the Revenue and Customs Commissioners against a decision of the First-tier Tribunal (Tax Chamber) to the effect that a disposal of cash by the taxpayers of two loan notes did not bring into charge an accrued capital gain. The tribunal decided that the effect of the conversion of those loan notes fell to be treated as one conversion to which s 116(1) of the Taxation of Chargeable Gains Act 1992 applied so that on the conversion of the successor notes, the frozen gain was realised under s 116(10) of that Act.
Our call for sufficient resources for the justice system and for the Bar to scrutinise the BSB’s latest consultation
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James Onalaja concludes his two-part opinion series
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In a two-part opinion series, James Onalaja considers the International Criminal Court Prosecutor’s requests for arrest warrants in the controversial Israel-Palestine situation