Changing places

This blog has nothing to do with Christmas.  I don’t have a Christmas tree this year (first time ever) and so am not in festive mood.  If you are looking for Christmas cheer, look elsewhere.  Instead I am going to talk to you about VAT.

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Butterfingers

Gains (and losses) on disposals of assets are, broadly, computed by deducting allowable expenditure from the disposal proceeds.  Section 49(1)(c) TCGA 1992 provides that no allowance is made in the first instance for ‘any contingent liability in respect of a warranty or representation made on a disposal by way of a sale or lease of property other than land’.  However where such a contingent liability becomes enforceable and is enforced, an adjustment can be made (section 49(2)).

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Nanny knows best

‘A nudge, as we will use the term, is any aspect of the choice architecture that alters people’s behaviour in a predictable way without forbidding any options or significantly changing their economic incentives. To count as a mere nudge, the intervention must be easy and cheap to avoid.’ (Cass R Sunstein and Richard H Thaler (2008), ‘Nudge: Improving Decisions about Health, Wealth and Happiness’)

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Sheep may safely graze

As you will know if you read my September 2014 blog, from time to time I suffer from insomnia.  Since the beginning of August it’s been so bad that my partner suspects I may been reprogrammed by eco-warriors for Economy 7 operation.  I seem to work best between the hours of two and seven in the morning.  Outside those hours I run on adrenaline and occasionally have to be hooked up to a double espresso drip…

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In the hot seat

The Excello law summer conference took place on 1 July, the UK’s hottest day for 13 years.  Skimming the conference programme on the way to Stapleford Park, I realised that I was down to give a 20 minute ‘tax insight’ qualifying for CPD points. As I had thought I was going to talk about myself for 20 minutes (an easy task for any lawyer) this meant I had around an hour and a half to get something technical together.

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Where the wild things are

Until I was ten I wanted to be a vet.  My best friend Ingrid’s dad was one.  Ingrid and I used to peer through the window and watch him doing operations.  I remember finding a frog with a swollen leg on my way back from my music lesson and taking it to Ingrid’s dad for a diagnosis…

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EBTs: an update after the end of EBTSO – Jo Summers and Jeremy Glover

HMRC withdrew its Employee Benefit Trust (‘EBT) Settlement Opportunity (the ‘EBTSO’) earlier this year.  Until 31 March 2015, HMRC were offering employers of beneficiaries under EBTs a way of settling the uncertainty relating to the taxation of the EBT.

Such uncertainty might relate to HMRC’s stated opinion that the creation of sub-trusts, or the making of loans, to beneficiaries always constituted the making of a taxable distribution to the beneficiary.

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