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R & C Commrs., [2012] EWCA Civ 927 (CA)-- summary under Tax Avoidance Summary Under Tax Topics- General Concepts- Tax Avoidance In order to shelter a capital gain which he had realized, the UK taxpayer purchased two options on the FTSE 100 index to be settled in cash: a put option (Option 1"); and a call option ("Option 2") with essentially the same strike price. ...

R & C Commrs v. Mertrux, [2012] UKUT 274 (Tax and Chancery Chamber)-- summary under Section 167.1 Summary Under Tax Topics- Excise Tax Act- Section 167.1 The taxpayer was a Mercedes dealer, licensed through Daimler-Chrysler UK ("DCUK"). ...

R & C Commrs v. Mertrux, [2012] UKUT 274 (Tax and Chancery Chamber)-- summary under Cumulative Eligible Capital Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital The taxpayer was a Mercedes dealer, licensed through Daimler-Chrysler UK ("DCUK"). ...

Lockyer & Anor (for Pawson Estate), [2013] UKUT 050 (Tax and Chancery Chamber)-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business actively-manged holiday property an investment The deceased taxpayer and her three children held equal interests in a bungalow ("Fairhaven"), which they rented out as a holiday property. ...

Lockyer & Anor (for Pawson Estate), [2013] UKUT 050 (Tax and Chancery Chamber)-- summary under Investment Business Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Investment Business actively-managed rental property an investment business The deceased taxpayer and her three children held equal interests in a bungalow ("Fairhaven"), which they rented out as a holiday property. ...

Acornwood LLP & Ors v. Revenue and Customs Commissioners, [2016] BTC 517, [2016] UKUT 0361 (Tax and Chancery Chamber)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose regard had to the actual use of the taxpayer's expenditure by the expenditure’s recipient where so directed by taxpayer In the appeal before him by five limited liability partnerships (the “LLPs”) respecting the disallowance of expenditures as trading losses, Nugee J indicated (at para. 6) that he was content to proceed on the basis of a simple example provided by the LLPs’ counsel using the figure of 100 to represent sums contributed to an LLP by individual members. ...

Leekes Ltd v HM Revenue & Customs, [2018] EWCA Civ 1185-- summary under Subparagraph 111(5)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a)- Subparagraph 111(5)(a)(ii) ability of successor to apply predecessor losses to income from same trade did not extend to profits from an enlarged trade The taxpayer (Leekes) carried on a trade of running department stores (three in Wales and one in Wiltshire) and acquired for nominal consideration all the shares of another company (Coles) that carried on a similar trade from three furniture stores and a distribution centre in the West Midlands. ...

Shanda Games Ltd v Maso Capital Investments Ltd & Ors (Cayman Islands), [2020] UKPC 2-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares minority discount to minority bloc of public-company shares The respondent (Shanda) was an exempted limited company incorporated in the Cayman Islands whose American Depository Shares (“ADSs”) were listed on the NASDAQ. ...

Galea v The Assessment Review Committee & Anor (Mauritius), [2025] UKPC 17-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit whether an activity qualifies as “carried on with a view to profit" turns on the taxpayer’s subjective intention Whether the taxpayer could deduct his 92% share of the losses incurred by a Mauritius partnership (of which he was the dominant partner) from his other sources of income turned on whether the partnership was carrying on a “business,” whose definition in the Mauritian Income Tax Act 1995 relevantly referred to "any trade, profession, vocation or occupation, manufacture or undertaking, or any other income earning activity, carried on with a view to profit. ...

Deloitte & Touche, LLP, 2014 DTC 5082 [at at 7068], 2014 BCSC 1083-- summary under Negligence, Fiduciary Duty and Fault Summary Under Tax Topics- General Concepts- Negligence, Fiduciary Duty and Fault tax contingency fee to auditors did not engage conflict of interest; internal memo not relevant to actual advice The defendant ("D&T"), which was the auditor of the plaintiff (Taiga), recommended that Taiga adopt a plan to minimize provincial taxes, relying on a "loop hole" in the Corporations Tax Act (Ontario), which permitted interest paid to an affiliate incorporaated outside Canada but which was resident in Canada to be received by it free of Ontario corporate tax. ...