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Blumenthal v Revenue and Customs Commissioners First-tier Tribunal (CAPITAL GAINS TAX/TAXATION OF CHARGEABLE GAINS) [2012] UKFTT 497 (TC) (08 August 2012)
URL: http://www.bailii.org/uk/cases/UKFTT/TC/2012/TC02174.html Cite as:
[2012] SFTD 1264,
[2012] STI 3236,
[2012] UKFTT 497 (TC)
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Blumenthal v Revenue and Customs Commissioners First-tier Tribunal (CAPITAL GAINS TAX/TAXATION OF CHARGEABLE GAINS) [2012] UKFTT 497 (TC) (08 August 2012)
CAPITAL GAINS TAX tax avoidance scheme whether Appellant's loan notes were converted to qualifying corporate bonds for the purposes of sections 116 and 117 TCGA 1992 whether steps taken to reduce the market value of loan notes effective for capital gains tax purposes purposive onstruction and the application of the Ramsay principle error in drafting amendments to loan notes principles of contractual interpretation whether HMRC entitled to raise a discovery assessment under section 29 TMA 1970 whether the officer could reasonably be expected to be aware of the insufficiency appeal dismissed
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