satisfaction

"BACK THEN IT WAS X & O,
NOWADAYS ITS JUST TIC-TAC-TOE"

Chris Band$:
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Tic-Tac-Toe (prodmarkcus, mercee & spyder)

St Celfer returns with tracks culled from a series of live shows, each one a showcase for his inventive experimentalism. 
Bandcamp New & Notable Jun 26, 2023

Lives

Bandcamp

Fifty One (Live at TAC Temescal Art Center, Oakland, 2023)

No episódio 569, você vai escutar sobre Trabalho temporário, Simples Nacional – Atualização e MDF-e

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Ep. 569:  Trabalho temporário / Simples Nacional – Atualização / MDF-e

This podcast discusses the Tax Appeals Commission (TAC) concerning an appeal against amended corporation tax (CT) assessments issued by the Revenue Commissioners for the years 2017 to 2022. The Appellant, a company that owned a hotel, contested the assessed liability of over €420,000, arguing that interest payments on loans used to acquire the hotel exceeded its rental income, resulting in a nil liability. The core issue before the Commissioner was whether the Appellant could claim a deduction for interest under Section 97(2)(e) of the Taxes Consolidation Act 1997, which hinged on proving the existence of qualifying loans and the actual discharge of interest payments. Ultimately, the Commissioner found the Appellant’s financial statements and records to be wholly unreliable and concluded that the Appellant failed to prove that it took out the necessary loans or paid the interest, leading to the appeal being dismissed.

216TACD2025 - Corporation Tax

This podcast discusses the Tax Appeals Commission concerning an appeal brought by an Appellant against the Revenue Commissioners regarding an amended Capital Gains Tax assessment for the tax year 2023. The core issue of the appeal is whether the Appellant could offset a loss incurred from the sale of a property to a "connected person" (specifically, the Appellant's son) in 2022 against a capital gain from the disposal of shares to a third party in 2023. The Appellant argued that the property sale was, in reality, an "arm’s length" transaction despite the familial connection, but the Commissioner ultimately determined that Section 549(3) of the Taxes Consolidation Act 1997 clearly and unambiguously restricts the deduction of such a loss only to gains accrued on disposals made to that same connected person. Consequently, the Commissioner ruled against the Appellant, confirming that the Revenue Commissioners' assessment to disallow the loss deduction was correct under the established law.

217TACD2025 - CGT

This podcast discusses a Tax Appeals Commission Determination (218TACD2025) concerning an appeal filed against the Revenue Commissioners regarding an underpayment of the Universal Social Charge (USC) for the tax year 2024. The Appellant, a retired Civil Servant who turned 70 in 2024, challenged a Statement of Liability for €697.76 after the Revenue initially granted him a reduced USC rate based on his age, only to revoke it when an in-year review established his income exceeded the €60,000 threshold required for the reduced rate. The core of the appeal revolves around the Appellant arguing that the underpayment was due to Revenue's error and imprudence in applying the reduced rate initially, while the Commissioner’s analysis relies on the plain wording of Section 531AN of the Taxes Consolidation Act 1997 (TCA 1997) to confirm that, because the Appellant's income exceeded the limit, the higher USC rates were correctly applied, ultimately determining that the Appellant had not met the burden of proof to overturn the tax liability.

218TACD2025 - USC

This podcast discusses the Irish Tax Appeals Commission concerning an appeal against the Revenue Commissioners. This case revolves around an Appellant who was required to repay a portion of the Help-to-Buy relief they received because they sold their property within the required five-year occupation period. The core issue is the clawback of €13,560, which represents sixty percent of the original €22,600 relief, triggered because the sale occurred in the third year of occupation. While the Appellant argued that extenuating circumstances, such as the housing crisis and purchasing a house that was initially unsuitable for their family, should warrant waiving the repayment, the Appeal Commissioner determined that the relevant legislation, section 477C of the TCA 1997, uses the mandatory term “shall,” leaving no discretion to reduce or relieve the required repayment. Consequently, the Commissioner ruled that the Revenue Commissioners’ decision to require the repayment of €13,560 must stand.

220TACD2025 - Help to Buy Scheme

This podcast discusses the Tax Appeals Commission (221TACD2025), concerning an appeal between an Appellant and the Revenue Commissioners regarding a refusal for a stamp duty repayment. The core issue is the Appellant's claim for a refund under Section 83D of the Stamp Duty Consolidation Act 1999 (SDCA), which provides for repayment if construction commences within 30 months of the instrument's execution date. The Respondent refused the claim because construction on the site began on March 29, 2024, which was more than 30 months after the instrument's execution date of March 5, 2020. The Appeal Commissioner ultimately determined that the Appellant failed to meet the statutory burden of proof and the clear requirements of the legislation, specifically Section 83D(3)(a) SDCA 1999, and therefore upheld the Revenue Commissioners’ decision to refuse the €5,500.00 repayment claim.

221TACD2025 - Stamp Duty

aint the 80s

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