The Revenue Commissioners v Collins [2016] IEHC 748 … The Revenue Commissioners -v-
Collins … [2016] IEHC 748 … Neutral Citation [2016] IEHC 748
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The Revenue Commissioners v Collins [2017] IECA 264 … Appeal in relation to The Revenue Commissioners v Collins [2016] IEHC 748 … The Revenue Commissioners -v- Collins … THE REVENUE
COMMISSIONERS
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97 Computational rules and allowable deductions (Direct Tax Acts, Finance Act 2022)
Subject to this Chapter, the amount of the profits or gains arising in any year shall for the purposes of Case V of Schedule D be computed as follows: … if no such contract exists, satisfies the Revenue Commissioners that the foundation for that building or that part of that building was laid in its entirety before the 23rd day of April, 1998.
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V … REVENUE COMMISSIONERS...DETERMINATION...is also complicated because the meaning of ‘profession’ and ‘professional services’ is notdefined in statute. For that reason, I have set out below a guide to the contents of thisdetermination....Page...CONTENTS...1-2...Introduction...Contents...2-3...4-5...Background...6-7...Legislation...8...Matters not is disputeEvidence...9 Documentary evidenceWitness e … REVENUE COMMISSIONERS … DETERMINATION...is also complicated because the meaning of ‘profession’ and ‘professional services’ is notdefined in statute. For that reason, I have set out below a guide to the contents of thisdetermination....Page...CONTENTS...1-2...Introduction...Contents...2-3...4-5...Background...6-7...Legislation...8...Matters not is disputeEvidence...9 Documentary evidenceWitness evidence:9-10...-the Comp … 1) The Commissioners of Inland Revenue v Maxse (1919) 12 TC 41 … 2) IRC v Ransom (William) & Son Ltd (1918)...3) Mac Giolla Mhaith (Inspector of Taxes) v Cronin & Associates Ltd...4) Emil Prodanov v Revenue Commissioners (2016 IEHC 708)...Interpretation of Statutes...1) Revenue Commissioners v Doorley (1933), IR750...2) Inspector of Taxes v Kiernan (1981) IR 117...3) McGrath V McDermott (1988) IR 258...4) Texaco (Ireland) v Murphy (1991)...5) Cork County Counc … IRC v … Ransom...(William) & Son Ltd (1918)... 3) Mac Giolla Mhaith (Inspector of Taxes) v Cronin & Associates Ltd...4) Emil Prodanov v Revenue Commissioners (2016 IEHC 708)...Interpretation of Statutes...1) Revenue Commissioners v Doorley (1933), IR750...2) Inspector of Taxes v Kiernan (1981) IR 117...3) McGrath V McDermott (1988) IR 258...4) Texaco (Ireland) v Murphy (1991)...5) Cork County Council V Wh
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Time is Ticking on Statutory Refund Claims for the NPPR Charge (Irish Tax Review 2017 Issue 2)
The Revenue Commissioners v Thomas Collins … [2016] IEHC 748 has upheld a 2013 Appeal Commissioners’ decision that the ordinary meaning of “any rate levied by a local authority”, in accordance with the computation of Case V rental income rules contained in s97(2)(b) TCA 1997, includes the Non-Principal Private Residence (NPPR) charge. … The Revenue Commissioners in eBrief No. 25/2017 have confirmed that they are referring the High Court’s decision to the Court of Appeal and that no refunds or amendments of returns will be processed until the appeal is decided. There are statutory provisions relating to a general right of repayment of... … TCA 1997 provides for the computation rules and allowable deductions against Case V rental income. In particular, s97(2)(b) provides for authorised deductions against rental income:
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6.5 Deductible Expenses (Practical Income Tax - The Professional's Guide 2023)
The Case V rules prescribe certain general principles to determine if specific expenses, detailed below, are deductible against rental income. These general rules can be summarised as follows: … An approved retrofitting grant (either an Individual Energy Upgrade Grant, the One Stop Shop Service, any other grant administered by the SEAI or any grant similar in nature to these grants designated as approved by the Revenue Commissioners) was received in respect of the works. … Expenditure of a capital nature unless specifically allowed, such as Case V capital allowances (see 6.7), property incentives (see 6.9) and s23 relief (see 6.10). Revenue is of the view that when a property is acquired, costs to bring it to a state that it can be rented are capital in nature. Therefore,... … The Revenue Commissioners v Collins [2016] IEHC 748
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provides that for a property that has been vacant for
at
least 12 months, expenditure incurred prior to the first letting of
that
property after the passing of FA17 will be deductible for Case V
purposes if it
would have qualified for deduction under … One item that had been repeatedly
debated with various clients from its introduction in 2009 to its
abolition in
2013 was the deductibility for Case V purposes of the Non-Principal
Private
Residence (“NPPR”) charge. permits the deduction for Case V purposes of
any
sum borne by the person chargeable …
The Revenue
Commissioners v Collins [2016] IEHC 748 …
The Revenue
Commissioners v Collins [2017] IECA 264
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