New guidance on Mansworth v Jelley capital losses

New guidance on Mansworth v Jelley capital losses

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Am not entirely clear on this and would appreciate some clarification please...

Mansworth v Jelley losses arose 1997/98 as a result of the simultaneous exercise and sale of unapproved options, claimed in Tax Return and never enquired into (thus final and conclusive).

Looking at HMRC's new guidance, does this mean that these established losses can still be carried forward and set-off against future gains? If not, what is the real effect of the new guidance?

Thanks

Colin

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By Ronnie Stanley
24th Jun 2009 13:39

No one seems to know yet
The ICAEW Tax Faculty is pressing HMRC to come & out & say what their revised 'guidance' really means in practical terms (per Tax Faculty update 9 Jun 09)

Suspect it will take a while to get a decent reply. Took them (HMRC) 6 years to come up with Brief 30/09.

Regards

Ronnie Stanley.

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