October has been a busy month this year in the tax world. As ever, Peter Vaines’ Tax Bulletin provides a reliable and quick digest of all the key matters in the past few weeks. The bulletin considers the detail of the cases of Vignes and Butler and what they mean for inheritance tax and business property relief going forwards. As ever, there is practical guidance concerning the ever-present issue of carelessness in a tax context – this time with respect to the time limits for the issuing of assessments and liability to penalties. The recent case of Delphi has thrown much of this into the spotlight of late, and the bulletin considers how the decision handed down by the FTT sits with the cases of Bella Figura and Magic Carpets.
If that were not enough to whet your appetite, then there are some useful reminders with respect to remittances and collateral along with a detailed consideration of the recent case of Lee and the factors to be borne in mind as set out by the Upper Tribunal when it comes to CGT and principal private residence relief. Helpfully, the bulletin reminds us of the clarity of the Supreme Court’s judgment in Vermilion and the position with respect to the deeming provision under ITEPA 2003, section 471. As always, happy reading!