CG39100P - Capital Gains Manual: Trusts and Capital Gains Tax: Non-resident trusts: Anti-avoidance legislation – flip-flop schemes: History TCGA92/Sch4B and 4C: contents
TRUSTS AND CAPITAL GAINS TAX
Non-resident trusts
Anti-avoidance legislation - flip-flop schemes
History TCGA92/Sch4B and 4C
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CG39100History TCGA92/Sch4B and 4C
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CG39105TCGA92/Sch4B - transfers of value linked to trustee borrowing – outline
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CG39110TCGA92/Sch4B – applies only to non-resident settlements
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CG39115TCGA92/Sch4B – transfer of value
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CG39120Transfer creates a new asset
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CG39125TCGA92/Sch4B – "the material time"
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CG39130TCGA92/Sch4B - What is trustee borrowing?
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CG39135TCGA92/Sch4B - 'proceeds' of trustee borrowing
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CG39140TCGA92/Sch4B – transfer of value linked with trustee borrowing
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CG39145TCGA92/Sch4B - Application of proceeds of borrowing for normal trust purposes
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CG39150TCGA92/Sch4B - payment in respect of ordinary trust assets
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CG39155Meaning of 'ordinary trust assets'
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CG39160Alternative test for TCGA92/Sch4B/para6(2)(b) to apply
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CG39165Borrowing to acquire freehold interest let on a commercial basis
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CG39170TCGA92/Sch4B - discharge of a loan obligation
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CG39175TCGA92/Sch4B - payment of ordinary trust expenses
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CG39180TCGA92/Sch4B - deemed disposal of remaining chargeable assets
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CG39185Deemed disposal – defined terms
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CG39190Disposal of the whole or part of each asset?
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CG39195Re-acquisition cost of assets
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CG39200TCGA92/Sch4B - value of asset attributable to trustee borrowing – outline
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CG39205Value of asset attributable to trustee borrowing – detail
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CG39210TCGA92/Sch4B - tax charge