Irish Capital Gains Tax provides in-depth analysis and interpretation of the law as it applies to CGT by the Irish and UK courts as well as the Appeal Commissioners' decisions. It also includes commentary on Revenue guidance, administration of capital gains tax, computational rules and key reliefs and allowances. Topics covered range from the tax treatment of married couples, partnerships, companies and trusts to anti-avoidance.
Contents:
1.Overview of statutory interpretation vis-a-vis UK ina CGT context.
2.How a chargeable gain arises - detail of meaning of disposal etc
3.Persons chargeable - what is within the scope - non-residents - is a loan an interest in land - discussion of revenue e-briefs etc.
4.Treatment of married couples, partnerships etc
5.Taxation of partnerships
6.Computational rules - discussion of meaning of consideration given/received
7.When does a disposal occur
8.Basic reliefs from CGT - principal private residence, requirement relief, charities
9.Share dealings, company buying its own shares, share reorganisations with discussion of most recent caselaw on point etc
10.Financial instruments, funds etc
11.Treatment of debts, debt on securities etc
12.Tax treatment of trusts
13.Anti-avoidance - I have written the only dedicated text in the country on General anti-avoidance.
14.Taxation of companies, group relief, capital gains clearance certs etc.
15.Differing treatment of individuals depending on residence status and double tax relief
16.Discussion of Companies Act 2014 transactions.