Surely there are two separate points to your post.
There was an option to tax on a residential property and therefore the purchaser paid VAT on the purchase. (very unlikely). Your client either opted to tax or did not - if they did VAT charged from date there was an option to tax.
or
The seller breached the VAT threshold themselves in the course of their trade, presumably as this fell into the scope of holiday accommodation it was subject to standard rate of VAT. Whether or not they were VAT registered and doing this property is not your problem.
You would therefore be left with a residential property held by a limited company with no option to tax.
You were required to register for VAT when your client's company's turnover reached the threshold (rather than day one).
The previous call, the gentleman at HMRC got himself so wound up that he threatened bankruptcy and suggested that the company pay the tax immediately because it wasn't his department's fault the carry back claims were taking so long.
Any tax return that goes out in December or January has a sentence at the end of the covering letter along the lines of - if the return is not filed by 31 January there will be a £100 late filing penalty.
As curtesy I would follow up once in the last week if they are a usual suspect.
A claim for capital allowances may be made, AMENDED or withdrawn at any time up to the first anniversary of the filing date for the company tax return of the claimant company for the accounting period for which the claim is made.
You state that the client is TRADING and investing crypto.
A ‘disposal’ includes: exchanging cryptoassets for cash or for a different type of cryptoasset;
My two cents on this is that if your client put £10,000 into a crypto platform and purchased £10,000 of Litecoin and the Litecoin increased to £20,000. If any any point he traded this Litecoin for another coin he has made a disposal for UK CGT purposes.
So unless your client has simply injected cash into a platform and never exchanged currencies you may be ok, but I highly doubt that is the case.
You would need to work out his residence position under the SRT test and then the CGT treatment would follow.
My answers
Surely there are two separate points to your post.
There was an option to tax on a residential property and therefore the purchaser paid VAT on the purchase. (very unlikely). Your client either opted to tax or did not - if they did VAT charged from date there was an option to tax.
or
The seller breached the VAT threshold themselves in the course of their trade, presumably as this fell into the scope of holiday accommodation it was subject to standard rate of VAT. Whether or not they were VAT registered and doing this property is not your problem.
You would therefore be left with a residential property held by a limited company with no option to tax.
You were required to register for VAT when your client's company's turnover reached the threshold (rather than day one).
The previous call, the gentleman at HMRC got himself so wound up that he threatened bankruptcy and suggested that the company pay the tax immediately because it wasn't his department's fault the carry back claims were taking so long.
No need for an educated guess, just look on Companies House.
Should you also be considering the market value of the property?
Any tax return that goes out in December or January has a sentence at the end of the covering letter along the lines of - if the return is not filed by 31 January there will be a £100 late filing penalty.
As curtesy I would follow up once in the last week if they are a usual suspect.
Info received by client before 21 January = usual charge out rate
Info received after said date = premium charge out rate
The company could reclaim the tax due on the write off.
However, you need to look at ITTOIA 2005/s419(2)
Amounts from the release of loans to a participator in a close company where the participator has died are treated as aggregate income of the Estate.
https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-...
A claim for capital allowances may be made, AMENDED or withdrawn at any time up to the first anniversary of the filing date for the company tax return of the claimant company for the accounting period for which the claim is made.
You state that the client is TRADING and investing crypto.
A ‘disposal’ includes: exchanging cryptoassets for cash or for a different type of cryptoasset;
My two cents on this is that if your client put £10,000 into a crypto platform and purchased £10,000 of Litecoin and the Litecoin increased to £20,000. If any any point he traded this Litecoin for another coin he has made a disposal for UK CGT purposes.
So unless your client has simply injected cash into a platform and never exchanged currencies you may be ok, but I highly doubt that is the case.
You would need to work out his residence position under the SRT test and then the CGT treatment would follow.
As long as the company owns the asset and is entitled to the income I would agree that the WHT can be deducted on the basis of the other posts.
Are you happy that the company owns the underlying asset that generates the income?
Too many musicians start a limited company and just change the bank details at PPL to their limited which causes a lot of issues down the line.