Search for: "Share v. Commissioner of Revenue"
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14 Mar 2012, 4:25 am
Revenue and Customs Commissioners v First Nationwide [2012] EWCA Civ 278; [2012] WLR (D) 73 “The tax status of preference dividends from a Cayman Islands company to whose shares the taxpayer had subscribed, was determined by the machinery by which they were distributed. [read post]
22 May 2012, 3:10 am
Humphreys v Revenue and Customs Commissioners [2012 UKSC 18; [2012] WLR (D) 154 “The indirect sex discrimination against fathers arising from the refusal to split child tax credit between separated parents who shared care of a child was objectively justified.” WLR Daily, 16th May 2012 Source: www.iclr.co.uk [read post]
1 Mar 2010, 3:54 am
Kellogg Brown & Root Holdings (UK) Ltd v Revenue and Customs Commissioners [2010] EWCA Civ 118; [2010] WLR (D) 53 “For the purposes of capital gains tax in relation to associated companies, under s 286(5)(b) of the Taxation of Chargeable Gains Act 1992, a ‘group’ did not require any common purpose but was to be given its ordinary meaning of ‘collection’. [read post]
16 Dec 2014, 6:38 am
On 27 and 28 October 2014 the UK Supreme Court heard Anson v The Commissioners for Her Majesty’s Revenue and Customs, a case concerning the taxation of the remitted income of an individual who is resident, but not domiciled, in the UK. [read post]
6 Mar 2018, 12:28 pm
Commissioner case. [read post]
25 Feb 2009, 2:28 pm
Haubrich v. [read post]
15 May 2022, 8:19 am
In this post, Hannah Jones, Assistant Professional Support Lawyer in the Tax team at CMS, comments on Commissioners for Her Majesty’s Revenue and Customs v Coal Staff Superannuation Scheme Trustees Ltd [2022] UKSC 10, a case which concerns the UK’s pre-2014 tax treatment of manufactured overseas dividends. [read post]
18 Apr 2016, 3:00 am
In particular, the Court applied its earlier decision in Memec plc v Commissioners of Inland Revenue [1998] STC 754, and determined that the decisive factor was that the LLC was the legal owner of the LLC’s assets, which generated the profit on which the LLC was subject to tax. [read post]
Case Preview: Prudential Assurance Company Ltd v Commissioners for Her Majesty’s Revenue and Customs
27 Mar 2018, 11:45 am
On Tuesday 20 and Wednesday 21 February 2018, the UK Supreme Court heard the appeal of Prudential Assurance Company Ltd v Commissioners for HMRC and the outcome is awaited. [read post]
21 Feb 2022, 6:58 am
In this post, Andre Anthony, a senior associate in the Tax team at CMS, previews the decision awaited from the UK Supreme Court in Commissioners for Her Majesty’s Revenue and Customs v NCL Investments Ltd and another EWCA Civ 663. [read post]
25 Aug 2021, 4:55 am
” In a case law context, the five principles governing estoppel by convention were outlined in the decision of Briggs J in Revenue and Customs Commissioners v Benchdollar [2009] EWHC 1310 (Ch) (“Benchdollar”). [read post]
28 Mar 2022, 2:38 am
In this post, Andre Anthony, a senior associate in the Tax team at CMS, comments on the decision of the UK Supreme Court in Commissioners for Her Majesty’s Revenue and Customs v NCL Investments Ltd and another [2022] UKSC 9. [read post]
19 Jan 2024, 9:16 am
The Supreme Court cited with approval its previous guidance given in the case of Fowler v Commissioners for Her Majesty’s Revenue & Customs [2020] UKSC 22 on the application of deeming provisions in legislation. [read post]
2 Jul 2021, 2:00 am
HMRC’s appeal to the Supreme Court raises two principal issues: first, whether HMRC formed the opinion required by section 205(3)(b) FA 2014, i.e., that “the principles laid down or reasoning given in Smallwood v Revenue and Customs Commissioners [2010] EWCA Civ 778 (“Smallwood”) would, if applied to [Mr Haworth’s] arrangements, deny the asserted advantage” (“Issue 1”); and second, whether HMRC… [read post]
14 Jul 2010, 3:00 am
In Veritas Software Corp. et. al. v. [read post]
30 Jul 2021, 4:24 am
The five principles governing estoppel by convention were outlined in the decision of Briggs J in Revenue and Customs Commissioners v Benchdollar [2009] EWHC 1310 (Ch). [read post]
9 Feb 2023, 8:34 am
In this post, Jack Prytherch, Of Counsel in the Tax team at CMS, previews the decision awaited from the Supreme Court in Commissioners for His Majesty’s Revenue and Customs v Vermilion Holdings Limited. [read post]
28 Jul 2021, 8:49 am
In this post, Tim Sales, a partner in the Dispute Resolution team at CMS, and Hannah Jones, who works in the Tax team at CMS, comment on the decision handed down by the UK Supreme Court in the matter of R (on the application of Haworth) v Commissioners for Her Majesty’s Revenue and Customs [2021] UKSC 25. [read post]
21 Feb 2017, 3:44 pm
In Summa Holdings, Inc. v. [read post]
22 Jul 2016, 3:55 am
Perhaps this was one step too far: although the Supreme Court was prepared to accept that the shares were not restricted securities, they were clearly shares. [read post]
