In J M Slade and another v HMRC the First-tier Tribunal ruled that the legal expenditure incurred defending rights to a number of assets collectively was not an allowable deduction for CGT purposes when one of those assets was sold alone. The case concerned two parcels of land which were transferred to the appellant and his son one of which was sold believing it to form part of the farmland left to him and his son. Some of the family asserted that the parcels formed part of the residuary estate in which they had an interest. As the asset in question had been sold by the time the expenditure was incurred the expenditure had not been in defending title to the asset but in defending title to the proceeds of sale of the asset. The FTT also ruled that there is no provision for apportionment of...
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In J M Slade and another v HMRC the First-tier Tribunal ruled that the legal expenditure incurred defending rights to a number of assets collectively was not an allowable deduction for CGT purposes when one of those assets was sold alone. The case concerned two parcels of land which were transferred to the appellant and his son one of which was sold believing it to form part of the farmland left to him and his son. Some of the family asserted that the parcels formed part of the residuary estate in which they had an interest. As the asset in question had been sold by the time the expenditure was incurred the expenditure had not been in defending title to the asset but in defending title to the proceeds of sale of the asset. The FTT also ruled that there is no provision for apportionment of...
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