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.
- What's the best software for this? 409 4
- Email encryption 1,400 15
- Auto enrolment confusion 1,191 22
- Next Move 737 21
- Zoho Books 167 1
- Separate companies same Director buy from each other 246 3
- Self-assessment statistics 2,495 59
- Entrepreneur - want to submit accounts by myself 322 5
- Transmission of ISA 142 2
- Bench-marking software, any ideas? 220 2
- Not renewing AAT 688 9
- CGT of shares gifted 389 6
- New dividend taxation 537 3
- Accountant won't release working papers 2,821 51
- Co purchase printed materials from EU - VAT 186 1
- Company car v company allowance 313 1
- Furnished Lettings - expenses normally bourne by tenant 444 9
- Company formation and bank account 468 9
- Owning overseas property 372 2
- MLR and benefitting from the disclosure 295 1
- Self employed and HMRC Worldwide Subsistence Rates 673
- Acrobat Checkbox Help for New 64-8 412
- Property letting & CAs 405
- 2015 tax year end 401
- Interest paid - do new rules affect Tax Credits? 399
- FCA regulated company in a small group 349
- Self employed consultant working in Ireland 324
- Market Invoice (P2P invoice discounting) tax treatment 244
- Costly Accounting Software contract 231
- DTA tie-breaker issue 221