The soon to be departed ‘fairly represents’ makes yet another appearance in a loan relationships case; this time taxing a £200m credit under a related transaction out of nothing in the GAAP compliant accounts. The purposive approach in a capital gains tax case on enhancement expenditure results in tax on more than economic profit absent any tax avoidance. HMRC responds to the decision of the Supreme Court in Anson on double tax relief for US LLCs.
