Dilution of Entrepreneur's Relief
Client owns shares in a limited company - 100% shareholder, also director.
5 years ago company built a property and received rental income.
1.5 years ago this property was sold and made a substantial gain (tax has been paid).
Company then used the net proceeds to fund a building project (with no intention to rent) which has been sold to a third party. Company is now building a third proeprty which is to be sold to a third party.
Up to the point when the first property was sold the company was an investement company, and then became a trading company when the building activities started.
If my client formally liquidates the company after selling the third property (and paying all the CT due on the trading activities), will he be entitled to full ER on the gain at liquidation? Or will there be a time apportionment between the period of being an investment company and being a trading company?
My reading of the legislation suggest that he will be entitled to ER in full but someone has suggested that I should check time apportionment.
- The stupidity continues 809 49
- transactions after account have been closed 217 5
- What is IRIS World like? 377 9
- Land Rover Discovery 3.0 SDV6 255 Comm Auto 2 seat 349 8
- Can I claim Vat on solicitors invoices? 224 6
- Limited company director - other earnings in the tax year 264 4
- CIMA at the age of 35?? 541 10
- Offsetting CT losses against another company 240 6
- Calculating capital gains tax for non-residents UK residential property 143 1
- CIS. Why is it so complicated? 2,343 25
- New Employers Helpline 213 4
- Software recommendations 284 1
- Share transfer question 393 17
- qualifying for 1/9th tax credit on foreign dividend 192 2
- HMRC & daft penalty 2,473 19
- Overlap relief 764 19
- Pension contributions 386 10
- Do you have to declare business expenditure on a personal credit card on your P11D? 520 11
- Do you use sign up lists on your website 225 1
- Setting up PAYE scheme without UTR 295 8
- Has anyone been affected by the RBS payment breakdown? 440
- Straight line write off of Purchase Goodwill ??? 438
- WIP Software 302
- FRS 102 compliant illustrative accounts for an insurance company 291
- No payroll scheme in place 236
- CGT, PPR and transfer of equity to spouse. 233
- Do subcontractors on work for residential (student accomodation) construction 212
- Is there anything wrong with this? 206
- Small Part Disposal of Property 192
- Uncommercial property business 183