Adrian Kerrison v Revenue & Customs (CAPITAL GAINS TAX/TAXATION OF CHARGEABLE GAINS : Computation) [2017] UKFTT 322 (TC)
Notes: Income tax and capital gains tax – “bed and breakfast” scheme to generate capital loss under s 106A TCGA – claim to income tax relief for the loss under s 574 ICTA 1988 – whether “repo” rules in s 263A TCGA, value shifting rules in s 30 TCGA or Ramsay principles applied to prevent loss arising – whether waiver of loan to appellant gave rise to a receipt subject to income tax under s 687 ITTOIA 2005 (income not otherwise charged) – appeal allowed in part
Cited in 4 later judgments