of course it is also convenient for the Revenue to specify that a Return isn't required where there is no gain....they don't want to be overrun by returns....but people will still need to check that a return isn't required....
I think the only issue with your whole response is the use of the word 'loan' on your second to last paragraph.....loans are repayable....which even in its 'retrospective' nature (if I were to concede that point) would mean that the individuals should expect to repay said loan....and the fact is that no one ever expected to repay these loans....that's why the scheme works......it is that simple.....really....
as mentioned have a chat with Justin, I am completely sympathetic but the law of unintended consequences that has caught you is because of the many who have avoided tax....and that Justin seeks to defend (because, he will claim his cases are exactly the same as you)
I would have a word with Justin, its the guys he is defending who have got us to this point. We have all been their....everyone is enjoying pushing the boundaries and then somebody (in this case many) decide to take the p.....so everybody gets treated the same.
You should point your anger in the direction of Justin and his band of brothers as much as the revenue.
Justin, perhaps rather than trying to corral us minions behind your campaign against the Revenue for their 'unfair' and 'retrospective' actions, why not get those tax barristers who backed these schemes in the first place...….
and there lies the problem....I don't think you will find many arguing with the incompetence of the Revenue (if any...haven't seen any such statements)….
the real scandal is that the primary (and in most case only) reason for entering this type of scheme was to avoid tax that the individual would have ordinarily paid. Setting it out as a loan (rather than income/salary etc)....but in the vast majority of cases one which was/is not repayable.
A classic case of someone trying to suggest that two wrongs do indeed make a right.....erm they don't!
I guess what I am asking is did someone, who was essentially employed, get given a loan that was to be repaid, then fail to repay said loan? too simple?....
Anybody wish to admit that these schemes only work if the individual involved doesn't need to repay the loan....anyone at all.....I don't need the reasons why they haven't or shouldn't need to....just that for the purposes of the scheme it don't work if they have to repay the loan....
...so they have or haven't been repaid...?! do you mean they invested the money in an investment which has risk attached....gave that asset in lieu of the loan but its value is such that the loan hasn't been fully settled? and....
My answers
of course it is also convenient for the Revenue to specify that a Return isn't required where there is no gain....they don't want to be overrun by returns....but people will still need to check that a return isn't required....
I think the only issue with your whole response is the use of the word 'loan' on your second to last paragraph.....loans are repayable....which even in its 'retrospective' nature (if I were to concede that point) would mean that the individuals should expect to repay said loan....and the fact is that no one ever expected to repay these loans....that's why the scheme works......it is that simple.....really....
has justin disappeared....?
as mentioned have a chat with Justin, I am completely sympathetic but the law of unintended consequences that has caught you is because of the many who have avoided tax....and that Justin seeks to defend (because, he will claim his cases are exactly the same as you)
I would have a word with Justin, its the guys he is defending who have got us to this point. We have all been their....everyone is enjoying pushing the boundaries and then somebody (in this case many) decide to take the p.....so everybody gets treated the same.
You should point your anger in the direction of Justin and his band of brothers as much as the revenue.
Justin, perhaps rather than trying to corral us minions behind your campaign against the Revenue for their 'unfair' and 'retrospective' actions, why not get those tax barristers who backed these schemes in the first place...….
and there lies the problem....I don't think you will find many arguing with the incompetence of the Revenue (if any...haven't seen any such statements)….
the real scandal is that the primary (and in most case only) reason for entering this type of scheme was to avoid tax that the individual would have ordinarily paid. Setting it out as a loan (rather than income/salary etc)....but in the vast majority of cases one which was/is not repayable.
A classic case of someone trying to suggest that two wrongs do indeed make a right.....erm they don't!
I guess what I am asking is did someone, who was essentially employed, get given a loan that was to be repaid, then fail to repay said loan? too simple?....
Anybody wish to admit that these schemes only work if the individual involved doesn't need to repay the loan....anyone at all.....I don't need the reasons why they haven't or shouldn't need to....just that for the purposes of the scheme it don't work if they have to repay the loan....
...so they have or haven't been repaid...?! do you mean they invested the money in an investment which has risk attached....gave that asset in lieu of the loan but its value is such that the loan hasn't been fully settled? and....
lets be clear....they are a sham.