This podcast concerns a First-Tier Tribunal Tax Chamber appeal regarding a capital gains tax assessment. The Appellant, Nicholas Millican, disputed the application of carried interest legislation to his tax return, arguing he did not perform investment management services for an investment scheme. The Tribunal examined the complex arrangement involving multiple partnerships, ultimately upholding the appeal because, although Millican performed investment management services, they were not performed "in respect of" an investment scheme as required by law. The decision hinges on a precise interpretation of statutory language concerning the definition of investment management services and the burden of proof regarding whether certain entities were investment schemes. The judgment provides a detailed analysis of relevant legislation and the evidence presented.

Nicholas Millican v HMRC [2024] UKFTT 618 (TC)

Le GHBS a officialisé fin janvier la signature de 10 contrats de pôles pour donner plus d'autonomie à chaque secteur. Mais pour la CGT, la réalité n'est pas là et l'objectif est purement financier. On en parle avec Ludovic Bénabès, représentant du personnel CGT du GHBS et Audrey Quémat, secrétaire de la coordination des syndicats CGT du GHBS.

PODCAST - GRAND LARGE, Au GHBS, des économies avant tout

This podcast details an application by Arshad Mahmood for permission to appeal a First-tier Tribunal (FTT) decision regarding a capital gains tax (CGT) assessment and associated penalty. The original FTT case concerned the disposal of properties by Mr. Mahmood to Rajay Khan Properties Limited. Mr. Mahmood challenged the assessment, arguing the property transfers were void due to a common mistake regarding CGT liability and that HMRC had not properly amended his tax return. The FTT rejected both arguments, leading to Mr. Mahmood's appeal application to the Upper Tribunal. Judge Jonathan Cannan ultimately denied permission to appeal, finding no arguable error of law in the FTT's decision, even with consideration of Mr. Mahmood's points regarding allegedly falsified documents and procedural errors.

Arshad Mahmood v HMRC [2025] UKUT 00050 (TCC)

The podcast discusses a determination from the Tax Appeals Commission of Ireland regarding a dispute between an Appellant and the Revenue Commissioners. The case concerns the capital gains tax treatment of the sale of a property that included plant and machinery on which capital allowances had been claimed. The Appellant argued for a single asset disposal calculation, while the Revenue Commissioners contended for separate computations for the land/buildings and the plant/machinery, leading to a higher tax liability. The Commission ultimately ruled in favor of the Appellant, finding no explicit statutory basis for the Revenue's method of apportionment and separate calculations in this specific scenario.

30TACD2025 - Capital Gains Tax

This week, the International Monetary Fund suggests a comprehensive capital gains tax, the Government will proceed with changes to the foreign investment fund regime and a novel proposal for helping fund New Zealand Superannuation.

The IMF calls for a comprehensive CGT, changes ahead for the FIF regime & a novel proposal for funding NZ Superannuation

O CGT (Carrier Genetic Testing), ou Teste Genético de Triagem de Portadores, é uma ferramenta poderosa que pode ajudar casais a tomarem decisões informadas sobre a saúde de seus futuros filhos.

Teste Genético CGT: O que você precisa saber para tomar decisões conscientes sobre a sua família

Hernán Madera Analista político

This podcast discusses a determination from the Tax Appeals Commission regarding an appeal by an individual against an amended capital gains tax assessment levied by the Revenue Commissioners. The dispute arose from a share for share exchange followed by a sale of shares, where the appellant had claimed tax relief under Section 586 of the Taxes Consolidation Act 1997. The Revenue argued that the exchange lacked bona fide commercial reasons and was part of a scheme aimed at tax avoidance. The Commission ultimately upheld the amended assessment, finding that the general offer for the share exchange did not meet the statutory requirements and that the transaction's main purpose was, at least in part, tax avoidance.

58TACD2025 - Capital Gains Tax

This podcast concerns the First-Tier Tribunal Tax Chamber's decision in the case of Mr. and Mrs. Morgan vs. The Commissioners for His Majesty’s Revenue and Customs regarding Capital Gains Tax. The core dispute revolved around whether a constructive trust transferred the beneficial interest in a property (Plot 3) to their company, D&R Property Development Ltd, in the 2015-2016 tax year, or if the taxable disposal occurred upon the legal transfer in 2016-2017. The tribunal ultimately found that a constructive trust did arise in the earlier tax year, transferring beneficial ownership due to the parties' express common intention and the company's detrimental reliance by incurring development costs. However, the tribunal also determined that a hypothetical HMRC officer could not have been reasonably expected to be aware of this constructive trust disposal by the relevant deadline for the 2015-2016 tax year. Consequently, the appeals against the 2016-2017 closure notices were allowed, while the appeals against the 2015-2016 protective assessments were dismissed.

Mr Roger William Morgan and Mrs Susan Joan Morgan v HMRC [2024] UKFTT 00565 (TC)

Si estás planeando tener hijos o considerando alternativas de reproducción asistida, es fundamental comprender los riesgos genéticos involucrados. El CGT (Carrier Genetic Testing), o Prueba Genética de Portadores, es una herramienta poderosa que puede ayudar a las parejas a tomar decisiones informadas sobre la salud de sus futuros hijos. Pero, ¿sabes cuál es la opción ideal para tu caso? Te explicamos todo sobre los diferentes tipos de cribado CGT, quiénes pueden realizarlas, qué significan los resultados y mucho más.

Estudio Genético CGT: Lo que Necesitas Saber para Tomar Decisiones Conscientes sobre Tu Familia.

This podcast discusses an Upper Tribunal (Tax and Chancery Chamber) appeal concerning Income Tax and Capital Gains Tax (CGT) related to a share buyback within the Enterprise Investment Scheme (EIS). The core issue revolves around whether the taxpayers' main purpose of obtaining EIS disposal relief, which reduces CGT to zero, necessarily implies a main purpose of obtaining an income tax advantage under sections 684 and 687 of the Income Tax Act 2007 (ITA 2007). The tribunal examines the distinction between the purpose of a transaction and its effect, citing the Blackrock HoldCo 5 v HMRC case, and ultimately allows the taxpayers' appeal, concluding that a CGT benefit does not automatically equate to an income tax advantage as a primary objective. The decision emphasizes that subjective intention is crucial in determining purpose and that an inevitable consequence is not necessarily a purpose.

Hugh Edward Mark Osmond v HMRC [2025] UKUT 183 (TCC)

Simple assessment and real-time reporting for capital gains tax (CGT) are two ways for HMRC and taxpayers to sidestep self assessment for income and gains.
HMRC sent out a record number of simple assessments for 2023/24. We explain what they are and explore some of the problem areas. We also explain how the often overlooked real-time reporting for CGT works and look at current issues with CGT reporting more generally.

Paying tax outside self assessment

If you're not a patron, subscribe at patreon.com/workstoppage to get full access to the episode.

In this third episode of our series on the class struggles on the US-Mexico border, we finish our high level overview of the political class struggle on the border from the end of the Mexican Revolution to the end of World War 2. With the consolidation of the Revolution in a liberal direction, we will discuss the attempts of workers to capitalize on their gains, and the Mexican state to control and contain their struggles. We cover the rise of nativist racism in the leadership of US trade unions and its counterproductive attacks on immigrant workers, as well as the efforts by radicals in the Communist and Socialist parties to change this and build true classwide unity. The Great Depression forced millions on both sides of the border to fight or starve and this period saw some of the greatest victories of mass working class industrial action. But without the consolidation of an independent political movement, the limitations of these efforts would become all too clear.

In the next sections of our series, we will focus in on the specifics of the labor struggles waged by workers in the fields, mines, and factories. We'll discuss the long history of attempts at multi-national unity in the labor struggle and both the successes and failures of the labor movement to rise to the challenge.

Join the discord: discord.gg/tDvmNzX 

Follow the pod at instagram.com/workstoppage, @WorkStoppagePod on Twitter,  John @facebookvillain, and Lina @solidaritybee

The Working Class Has No Border Ep 3: From Revolution to Repression PREVIEW

This podcast concerns a determination from the Tax Appeals Commission regarding an appeal concerning income tax and Capital Gains Tax (CGT) assessments. The Appellant challenged tax notices from the Revenue Commissioners related to distributions received from the liquidation of an offshore investment fund in 2017 and 2019. The central issue is whether the Appellant's interest in the fund constituted a "material interest" under tax law, which would subject the gains to income tax rather than CGT. The Commissioner relies heavily on a previous, similar determination (42TACD2024) to establish key material facts, concluding that the Appellant's investment was indeed a material interest, thus affirming the income tax assessments and reducing the CGT assessment to nil.

182TACD2025 - Income Tax & CGT

This podcast concerns a First-Tier Tribunal Tax Chamber decision on Mark Campbell's appeal against capital gains tax (CGT) assessments and penalties levied by HMRC concerning four properties he owned and sold between 2012 and 2016. The core of the dispute revolves around whether Campbell was entitled to the principal private residence (PPR) exemption from CGT, specifically on the grounds that his parents' home, where he resided, was job-related accommodation (JRA) and that he intended to occupy the properties he owned as his main residence. The tribunal's judgment details the complex history of appeals, including a prior First-Tier Tribunal decision and an Upper Tribunal ruling, before meticulously examining the legal criteria for JRA and Campbell's intent based on extensive medical, contractual, and witness evidence. Ultimately, the tribunal found in Campbell's favor, concluding that his living situation qualified as JRA and that he had the requisite intention to occupy the properties, thereby upholding his appeal against the tax liabilities and associated penalties.

Mark Campbell v HMRC [2025] UKFTT 867 (TC)

This week how Australian capital gains tax can apply to the sale of a New Zealand property, CPA Australia suggests it’s time to consider a capital gains tax, more on effective marginal tax rates and the meaning of 'payment' for GST purposes.

The perils of having an Australian resident trustee, CPA Australia suggests it's time for a CGT, and the meaning of 'payment' for GST purposes

This podcast discusses an appeal to the Tax Appeals Commission concerning a capital gains tax (CGT) assessment for the year ended December 31, 2023. The core of the dispute revolves around an Appellant's claim for negligible loss relief on shares held in Allied Irish Banks plc (AIB) and Irish Life and Permanent plc (IL&P), which the Revenue Commissioners denied. The appeal explores the interpretation of Section 538(2) of the Taxes Consolidation Act 1997, specifically the meaning of "negligible value" in the context of assets that have significantly declined in price but remain tradeable. The Commissioner ultimately determines that the value of individual shares must be considered, not the aggregate shareholding, and that the shares in question were not of negligible value as defined by law, despite substantial losses incurred by the Appellant. The determination confirms the original CGT assessment, highlighting the distinction between a significant loss in value and an asset becoming "worth next to nothing."

194TACD2025 - CGT

En este podcast Mario Rísquez (CGT) y Martín Lallana (Anticapitalistas) analizan los conflictos laborales que se darán vinculados a la crisis ecológica y las transformaciones productivas. Esta transformación se va a dar ligada al capital, dejando atrás a los trabajadores. Por lo que obliga a la izquierda revolucionaria a tener una capacidad defensiva para poder responder a estos ataques sin caer en posiciones negacionistas, pero al mismo acumular suficiente fuerza política y sindical para poder plantear otro tipo de transformaciones que tenga unos principios ecosocialista.

Uni Anticapi 2025

Transiciones ecosociales en el mundo del trabajo

Tthe recently released Taxation (Annual Rates for 2025−26, Compliance Simplification, and Remedial Measures) Bill is noteworthy for as much as what’s not included and do we really need a comprehensive capital gains tax, a provocative highlight from the New Zealand Law Society’s 2025 tax Conference. 

A deep(ish) dive into the recently released tax bill and highlights from the 2025 NZLS Tax Conference

Podcast impulsado por Anticapitalistas. Información y debate desde abajo para cambiar el mundo de base.

La radio locale N° 1 de Lorient Bretagne Sud.
Infos locales, tous les tubes, des jeux et cadeaux.

Igenomix, parte do Grupo Vitrolife, é um laboratório de genética especializado em medicina reprodutiva que oferece soluções para permitir a gravidez e o nascimento de um bebê saudável.

Tax changes how business and people live and work.  Each week we discuss tax news and how it affects you.  Tax is an important policy lever for Government and cross-border tax for global corporations is an issue for Tax and Fairness.

ICAEW is a professional membership organisation that provides insight and leadership to the global accountancy and finance profession.

New tracks tagged #cgt