Blumenthal v Revenue and Customs Commissioners First-tier Tribunal (CAPITAL GAINS TAX/TAXATION OF CHARGEABLE GAINS) [2012] UKFTT 497 (TC)
[1]Blumenthal v Revenue and Customs Commissioners First-tier Tribunal (CAPITAL GAINS TAX/TAXATION OF CHARGEABLE GAINS) [2012] UKFTT 497 (TC) (08 August 2012)[2]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[3]A HTML version of this file is not available click here or view below the pdf version : TC02174.pdf
Cited in 5 later judgments