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Carling Export Brew & Malt Co. v. The King, [1931] A.C. 435 (P.C.)-- summary under Regulations/Statutory Delegation Summary Under Tax Topics- Statutory Interpretation- Regulations/Statutory Delegation Regulation to implement an export exemption could be dispensed with A federal excise tax exemption for goods "manufactured for export, under regulations prescribed by the Minister of Customs and Excise" was applicable even though the Minister had made no regulations. ...

G E Financial Investments v.The Commissioners for Her Majesty's Revenue & Customs, [2021] UKFTT 0210 (Tax Chamber), ultimately aff'd [2024] EWCA Civ 797-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 UK would have been required to accord foreign tax credit to dual resident company if the US had imposed its taxes in accordance with the PE article A US company (“GEFI Inc.”) and UK company (“GEFI”) in the GE group formed a Delaware LP (the “LP”) with GEFI Inc. as the 1% general partner and GEFI as the 99% limited partner, LP made five intercompany loans and also received some loans from its partners as capital contributions. ...

Cheshire Cavity Storage 1 Ltd & Anor v Commissioners for Her Majesty's Revenue and Customs, [2022] EWCA Civ 305-- summary under Regulation 1102(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Regulation 1102(2) a cavity formed out of rock to store gas was not “plant” and was premises or land The taxpayer, which was engaged in the development, construction, and operation of gas storage facilities in the UK, was found not to be entitled to capital allowances in respect of the expenditure incurred on the introduction of water into salt bearing rock so as to dissolve the rock and create an impervious cavity (“leaching”), and the displacement of the resulting brine by the introduction of gas (“de-brining”) so as to permit the storage of gas in the cavity, on the basis that the cavities were not “plant” (an undefined term). ...

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"). ...

Wood & Anor v Inspector of Taxes Rev 1, [2006] EWCA Civ 26, 78 TC 1-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) taking advice from an outsider does not establish that the board was not exercising CMC At issue was whether a Netherlands corporation ("Eulalia") was resident in the United Kingdom. ...

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. ...