Property disposals 2: UK development deals

Article Abstract:

Section 776 of the Income and Corporation Taxes Act of 1988 (ICTA) allows the Board of Inland Revenue to re-categorize certain property disposals where a capital gain has been realized. S 776 may be applied to any property disposal where land is: acquired with the intent of realizing a gain upon disposal, held as trading stock, and developed with the intent to realize a gain upon disposal of the development. S 776 is applicable to property disposal regardless of whether the gain is realized by the person developing, holding, or acquiring the land.

Finance, taxation, & monetary policy, Real estate development, United Kingdom. Board of Inland Revenue, Great Britain

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Never can say goodbye

Article Abstract:

The concepts to be considered by owner-managers while planning to run and possibly during passing the control of the business to the next-generation are described. The tax strategies that will assist with effective succession planning relating to transfer of shares to the next generation, Capital Gains Tax (CGT) holdover relief, mechanics of s165 relief, and use of discretionary trust, are discussed.

United Kingdom, Tax Law, Public Finance Activities, Legal issues & crime, Government regulation (cont), Government regulation, Legal/Government Regulation, Capital Gains Taxes, Interpretation and construction

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Too hot to handle

Article Abstract:

Issues concerning the use of non-resident trusts as a means of avoiding UK capital gains tax are discussed, with focus on the tax treatment of the trusts since the rules were changed in the Finance Act of 1998.

Other Financial Vehicles, Trusts, not elsewhere classified, Trusts ex Ed, Religious, Charitable, Trusts and trustees, Trustees, Trusts (Law)

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