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The Ramsay Principle
"Ramsay principle" is the shorthand name given to the decision of the House of Lords in two important cases in the field of UK tax, reported in 1982: * ''Ramsay v. IRC'', the full name of which is ''W. T. Ramsay Ltd. v. Inland Revenue Commissioners, Eilbeck (Inspector of Taxes) v. Rawling'', and its citation is 982A.C. 300. * ''IRC v. Burmah Oil Co. Ltd.'', the full name of which is ''Inland Revenue Commissioners v. Burmah Oil Co. Ltd.'', and its citation is 982S.T.C. 30, H.L.(Sc.). In summary, companies that had made substantial capital gains had entered into complex and self-cancelling series of transactions that had generated artificial capital losses, for the purpose of avoiding capital gains tax. The House of Lords decided that where a transaction has pre-arranged artificial steps that serve no commercial purpose other than to save tax, the proper approach is to tax the effect of the transaction as a whole. The decision is not limited to capital gains tax, but applies to ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Judicial Functions Of The House Of Lords
Whilst the House of Lords of the United Kingdom is the upper chamber of Parliament and has government ministers, it for many centuries had a judicial function. It functioned as a court of first instance for the trials of peers, for impeachments, and as a court of last resort in the United Kingdom and prior, the Kingdom of Great Britain and the Kingdom of England. Appeals were technically not to the House of Lords, but rather to the King-in-Parliament. In 1876, the Appellate Jurisdiction Act devolved the appellate functions of the House to an Appellate Committee, composed of Lords of Appeal in Ordinary (informally referred to as Law Lords). They were then appointed by the Lord Chancellor in the same manner as other judges. During the 20th and early 21st century, the judicial functions were gradually removed. Its final trial of a peer was in 1935, and in 1948, the use of special courts for such trials was abolished. The procedure of impeachment became seen as obsolete. In 2009, t ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Lord Wilberforce Cases
Lord is an appellation for a person or deity who has authority, control, or power over others, acting as a master, chief, or ruler. The appellation can also denote certain persons who hold a title of the peerage in the United Kingdom, or are entitled to courtesy titles. The collective "Lords" can refer to a group or body of peers. Etymology According to the Oxford Dictionary of English, the etymology of the word can be traced back to the Old English word ''hlāford'' which originated from ''hlāfweard'' meaning "loaf-ward" or "bread-keeper", reflecting the Germanic tribal custom of a chieftain providing food for his followers. The appellation "lord" is primarily applied to men, while for women the appellation "lady" is used. This is no longer universal: the Lord of Mann, a title previously held by the Queen of the United Kingdom, and female Lords Mayor are examples of women who are styled as "Lord". Historical usage Feudalism Under the feudal system, "lord" had a wide ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Avoidance
Tax avoidance is the legal usage of the tax regime in a single territory to one's own advantage to reduce the amount of tax that is payable by means that are within the law. A tax shelter is one type of tax avoidance, and tax havens are jurisdictions that facilitate reduced taxes. Tax avoidance should not be confused with tax evasion, which is illegal. Forms of tax avoidance that use legal tax laws in ways not necessarily intended by the government are often criticized in the court of public opinion and by journalists. Many corporations and businesses that take part in the practice experience a backlash from their active customers or online. Conversely, benefiting from tax laws in ways that were intended by governments is sometimes referred to as tax planning. The World Bank's World Development Report 2019 on the future of work supports increased government efforts to curb tax avoidance as part of a new social contract focused on human capital investments and expanded social p ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
1982 In The United Kingdom
Events from the year 1982 in the United Kingdom. The year was dominated by the Falklands War. Incumbents * Monarch – Elizabeth II * Prime Minister – Margaret Thatcher (Conservative) * Parliament – 48th Events January * 1 January – ITV launches three regional TV stations – Central, TVS (Television South) and TSW (Television South West), replacing ATV Midlands, Southern Television and Westward Television respectively. * 2 January **The Welsh Army of Workers claims responsibility for a bomb explosion at the Birmingham headquarters of Severn Trent Water. **British Rail retires its last Class 55 Deltic diesel-electric locomotives from service. * 10–15 January – The lowest ever UK temperature of −27.2 °C is recorded at Braemar, in Aberdeenshire. This equals the record set in the same place in 1895, and the record will be equalled again at Altnaharra in 1995. * 11 January – Mark Thatcher, son of the Prime Minister Margaret Thatcher, disappears in the Sah ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
1982 In Law
__NOTOC__ Year 198 (CXCVIII) was a common year starting on Sunday (link will display the full calendar) of the Julian calendar. At the time, it was known as the Year of the Consulship of Sergius and Gallus (or, less frequently, year 951 ''Ab urbe condita''). The denomination 198 for this year has been used since the early medieval period, when the Anno Domini calendar era became the prevalent method in Europe for naming years. Events By place Roman Empire *January 28 **Publius Septimius Geta, son of Septimius Severus, receives the title of Caesar. **Caracalla, son of Septimius Severus, is given the title of Augustus. China *Winter – Battle of Xiapi: The allied armies led by Cao Cao and Liu Bei defeat Lü Bu; afterward Cao Cao has him executed. By topic Religion * Marcus I succeeds Olympianus as Patriarch of Constantinople (until 211). Births * Lu Kai (or Jingfeng), Chinese official and general (d. 269) * Quan Cong, Chinese general and advisor (d. 24 ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Taxation In The United Kingdom
Taxation in the United Kingdom may involve payments to at least three different levels of government: central government (HM Revenue & Customs), devolved governments and local government. Central government revenues come primarily from income tax, National Insurance contributions, value added tax, corporation tax and fuel duty. Local government revenues come primarily from grants from central government funds, business rates in England, Council Tax and increasingly from fees and charges such as those for on-street parking. In the fiscal year 2014–15, total government revenue was forecast to be £648 billion, or 37.7 per cent of GDP, with net taxes and National Insurance contributions standing at £606 billion. History A uniform Land tax, originally was introduced in England during the late 17th century, formed the main source of government revenue throughout the 18th century and the early 19th century.Stephen Dowell, ''History of Taxation and Taxes in England'' (Routledge ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
House Of Lords Cases
A house is a single-unit residential building. It may range in complexity from a rudimentary hut to a complex structure of wood, masonry, concrete or other material, outfitted with plumbing, electrical, and heating, ventilation, and air conditioning systems.Schoenauer, Norbert (2000). ''6,000 Years of Housing'' (rev. ed.) (New York: W.W. Norton & Company). Houses use a range of different roofing systems to keep precipitation such as rain from getting into the dwelling space. Houses may have doors or locks to secure the dwelling space and protect its inhabitants and contents from burglars or other trespassers. Most conventional modern houses in Western cultures will contain one or more bedrooms and bathrooms, a kitchen or cooking area, and a living room. A house may have a separate dining room, or the eating area may be integrated into another room. Some large houses in North America have a recreation room. In traditional agriculture-oriented societies, domestic animals such a ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Furniss V Dawson
''Furniss v. Dawson'' is an important House of Lords case in the field of UK tax. Its full name is ''Furniss (Inspector of Taxes) v. Dawson D.E.R., Furniss (Inspector of Taxes) v. Dawson G.E., Murdoch (Inspector of Taxes) v. Dawson R.S.'', and its citation is 984A.C. 474, or alternatively 9842 W.L.R. 226. Its effect was to extend the applicability of The Ramsay Principle. The Ramsay Principle The most important background to ''Furniss v. Dawson'' was the decision of the House of Lords a few years earlier in ''W. T. Ramsay Ltd. v. Inland Revenue Commissioners'' 982A. C. 300. In the Ramsay case, a company which had made a substantial capital gain had entered into a complex and self-cancelling series of transactions which had generated an artificial capital loss. The House of Lords decided that where a transaction has pre-arranged artificial steps which serve no commercial purpose other than to save tax, then the proper approach is to tax the of the transaction as a whole. ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Duke Of Westminster's Case
The ''Duke of Westminster's case'' was an often cited case in tax avoidance. The full title and citation was ''Inland Revenue Commissioners v. Duke of Westminster'' 936A.C. 1; 19 TC 490. The Duke of Westminster used to employ a gardener and pay him from his post-tax income, which was substantial. To reduce tax, the Duke stopped paying the gardener's wage and instead drew up a covenant, agreeing to pay an equivalent amount at the end of every specified period. Under the tax laws of the time, this allowed the Duke to claim the expense as a deduction, thus reducing his taxable income and his liability towards income tax and surtax. The Department of Inland Revenue challenged this arrangement as tantamounting to tax evasion and took the Duke to court. They however lost their case. The judge, Lord Tomlin, famously said: Every man is entitled, if he can, to order his affairs so that the tax attaching under the appropriate Acts is less than it otherwise would be. If he succeeds in orde ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Kenneth Diplock, Baron Diplock
William John Kenneth Diplock, Baron Diplock, (8 December 1907 – 14 October 1985) was a British barrister and judge who served as a lord of appeal in ordinary between 1968 and until his death in 1985. Appointed to the English High Court in 1956 and the Court of Appeal five years later, Diplock made important contributions to the development of constitutional and public law as well as many other legal fields. A frequent choice for governmental inquiries, he is also remembered for proposing the creation of the eponymous juryless Diplock courts. Of him, Lord Rawlinson of Ewell wrote that "to his generation Diplock was the quintessential man of the law". Early life and legal career Kenneth Diplock was born in South Croydon, the son of solicitor William John Hubert Diplock and his wife Christine Joan Diplock, ''née'' Brooke. He was educated at Whitgift School in Croydon and University College, Oxford, where he read chemistry and graduated with a second-class degree in 1929. He ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Subsidiary
A subsidiary, subsidiary company or daughter company is a company owned or controlled by another company, which is called the parent company or holding company. Two or more subsidiaries that either belong to the same parent company or having a same management being substantially controlled by same entity/group are called sister companies. The subsidiary can be a company (usually with limited liability) and may be a government- or state-owned enterprise. They are a common feature of modern business life, and most multinational corporations organize their operations in this way. Examples of holding companies are Berkshire Hathaway, Jefferies Financial Group, The Walt Disney Company, Warner Bros. Discovery, or Citigroup; as well as more focused companies such as IBM, Xerox, and Microsoft. These, and others, organize their businesses into national and functional subsidiaries, often with multiple levels of subsidiaries. Details Subsidiaries are separate, distinct legal entities f ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
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