Strand options and futures ltd v vojak
Strand Futures and Options Ltd v Vojak (HMIT) (2002) Sp C 328 [The appeal against this decision is reported at [2003] BTC 344.] Dr John F Avery Jones, Malcolm JF Palmer. Decision released 13 February 2002. Corporation tax – Chargeable gain – Purchase of own shares by company from taxpayer – Distribution treatment applicable – Whether The recent High Court decision in Strand Futures and Options Ltd v Vojak overturns Inland Revenue practice (Statement of Practice 4/89) and offers significant tax benefits to corporation tax-paying investors on share buy-backs. The Inland Revenue may appeal the decision or seek to reverse its effect by attempting to introduce new legislation. THE SPECIAL COMMISSIONERS STRAND FUTURES AND OPTIONS LIMITED Appellant - and - PETER WILLIAM LEWIS VOJAK Respondent Special Commissioners: DR JOHN F AVERY JONES CBE MALCOLM J F PALMER Sitting in public in London on Thursday 17 January 2002 Jan Matthews of counsel instructed by Fisher Sassoon & Marks, chartered accountants, for the Appellant Strand Options and Futures Ltd v Vojak. The High Court has provided an important judgment which throws doubt on the Inland Revenue' s view as expressed in Statement of Practice (SP) 4/89. Point at issue: The consideration for the purchase of own shares potentially falls into the computation of a chargeable gain in the hands of the seller, subject to any necessary matters to be taken into account under the chargeable gains legislation. This was confirmed by the judgement in the Court of Appeal in Strand Options and Futures Ltd v Vojak [2004] STC 64. Strand Options and Futures Ltd v Vojak [2004] STC 64 [16], and is relatively uncontroversial. Legislative conundrum Slightly more interesting is the new TCGA 1992, s 122(6) [10], which says that a distribution which is exempt under CTA 2009, Part 9A [6] cannot be a capital distribution chargeable under TCGA 1992, s 122 [10]. The judgement in the case of Strand Options and Futures Ltd v Vojak, 76 TC 220 CA, provides judicial interpretation of section 208 of ICTA. The Court of Appeal held that the exemption referred specifically to leaving dividends and other distributions out of account in computing income , which does not mean that the amount of a distribution
8 Jan 2009 Strand Options and Futures v Vojak [2004] STC 64. 2. Schedule 7AC of it generally does. 4. Rae v Lazard Investment Co Ltd (1963) 41 TC 1
I said"Tax treatment for company shareholder is not as Revenue s This matter has been considered in the High court and confirmed last week in the Court of Appeal in "Strand Options and Futures Ltd v Vojak (Inspector of Taxes) ", who have held that the disposal by the shareholding company is not a chargeable gain. A dividend received by one UK company from another UK company is not usually chargeable to Corporation Tax (although note the position of capital sums derived from assets and TCGA 1992 s 122, and the decision in Strand Options and Futures Ltd v Vojak [2004] STC 64). Consider a company which has a subsidiary standing at a significant gain with The recent High Court decision in Strand Futures and Options Ltd v Vojak overturns Revenue practice (SP4/89) and offers significant tax benefits to corporation tax paying investors on share buybacks. It is possible that the Revenue will appeal the decision or seek to reverse its effect by attempting to introduce new law. The Inland Revenue's appeal against the High Court decision in Strand Futures and Option Ltd v Vojak has been allowed. This returns the position to that set out in the Inland Revenue's Statement of Practice 4/89. For further details on the High Court decision, setting
8 Jan 2009 Strand Options and Futures v Vojak [2004] STC 64. 2. Schedule 7AC of it generally does. 4. Rae v Lazard Investment Co Ltd (1963) 41 TC 1
(1)The appellant was incorporated on 11 April 1986 under the name Amoptions UK Ltd and changed its name to Strand Options and Futures Ltd in December Strand Futures and Options Ltd v Vojak (HMIT). [2003] BTC 395. [2003] EWCA Civ 1457. Court of Appeal (Civil Division). Potter, Rix and Carnwath L JJ. 6 Apr 2019 References: Times 25-Feb-2003, [2003] EWHC 67 (Ch) Links: Bailii Ratio: The taxpayer had acquire by allotment a proportion of the issued 8 Jan 2009 Strand Options and Futures v Vojak [2004] STC 64. 2. Schedule 7AC of it generally does. 4. Rae v Lazard Investment Co Ltd (1963) 41 TC 1 4 Aug 2010 Strand Options and Futures Ltd v Vojak [2004] STC 64 [16], and is relatively uncontroversial. Legislative conundrum. Slightly more interesting is Futures and options are both derivatives that reflect movement in the underlying commodity, but which one should you be trading?
The recent High Court decision in Strand Futures and Options Ltd v Vojak overturns Revenue practice (SP4/89) and offers significant tax benefits to corporation tax paying investors on share buybacks. It is possible that the Revenue will appeal the decision or seek to reverse its effect by attempting to introduce new law.
Strand Futures and Options Ltd v Vojak (HMIT). [2003] BTC 395 [2003] EWCA Civ 1457. Court of Appeal (Civil Division). Potter, Rix and Carnwath L JJ. Judgment delivered 22 October 2003. Corporation tax Strand Futures and Options Ltd v Vojak (HMIT) (2002) Sp C 328 [The appeal against this decision is reported at [2003] BTC 344.] Dr John F Avery Jones, Malcolm JF Palmer. Decision released 13 February 2002. Corporation tax – Chargeable gain – Purchase of own shares by company from taxpayer – Distribution treatment applicable – Whether The recent High Court decision in Strand Futures and Options Ltd v Vojak overturns Inland Revenue practice (Statement of Practice 4/89) and offers significant tax benefits to corporation tax-paying investors on share buy-backs. The Inland Revenue may appeal the decision or seek to reverse its effect by attempting to introduce new legislation. THE SPECIAL COMMISSIONERS STRAND FUTURES AND OPTIONS LIMITED Appellant - and - PETER WILLIAM LEWIS VOJAK Respondent Special Commissioners: DR JOHN F AVERY JONES CBE MALCOLM J F PALMER Sitting in public in London on Thursday 17 January 2002 Jan Matthews of counsel instructed by Fisher Sassoon & Marks, chartered accountants, for the Appellant Strand Options and Futures Ltd v Vojak. The High Court has provided an important judgment which throws doubt on the Inland Revenue' s view as expressed in Statement of Practice (SP) 4/89. Point at issue: The consideration for the purchase of own shares potentially falls into the computation of a chargeable gain in the hands of the seller, subject to any necessary matters to be taken into account under the chargeable gains legislation. This was confirmed by the judgement in the Court of Appeal in Strand Options and Futures Ltd v Vojak [2004] STC 64. Strand Options and Futures Ltd v Vojak [2004] STC 64 [16], and is relatively uncontroversial. Legislative conundrum Slightly more interesting is the new TCGA 1992, s 122(6) [10], which says that a distribution which is exempt under CTA 2009, Part 9A [6] cannot be a capital distribution chargeable under TCGA 1992, s 122 [10].
The High Court has reversed the decision of the Special Commissioners in Strand Futures and Options Limited v Vojak Subject to an appeal by the Inland Revenue, this case decides how a corporate shareholder is taxed on sums that it receives from a company that purchases its own shares from the corporate shareholder.. A company is not subject to tax on the Schedule F dividends that it receives.
(1)The appellant was incorporated on 11 April 1986 under the name Amoptions UK Ltd and changed its name to Strand Options and Futures Ltd in December Strand Futures and Options Ltd v Vojak (HMIT). [2003] BTC 395. [2003] EWCA Civ 1457. Court of Appeal (Civil Division). Potter, Rix and Carnwath L JJ.
(1)The appellant was incorporated on 11 April 1986 under the name Amoptions UK Ltd and changed its name to Strand Options and Futures Ltd in December Strand Futures and Options Ltd v Vojak (HMIT). [2003] BTC 395. [2003] EWCA Civ 1457. Court of Appeal (Civil Division). Potter, Rix and Carnwath L JJ. 6 Apr 2019 References: Times 25-Feb-2003, [2003] EWHC 67 (Ch) Links: Bailii Ratio: The taxpayer had acquire by allotment a proportion of the issued 8 Jan 2009 Strand Options and Futures v Vojak [2004] STC 64. 2. Schedule 7AC of it generally does. 4. Rae v Lazard Investment Co Ltd (1963) 41 TC 1 4 Aug 2010 Strand Options and Futures Ltd v Vojak [2004] STC 64 [16], and is relatively uncontroversial. Legislative conundrum. Slightly more interesting is Futures and options are both derivatives that reflect movement in the underlying commodity, but which one should you be trading?