taxation advice - where to start?

DubsB

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I need to get professional advice regarding capital gains tax and am wondering where I start looking for someone. Can anyone point me in the direction of a company or individual who have a good reputation in this regard - or even a good place to start looking (as I'm not sure if individual recommendations are allowed here). I'm living abroad and just amn't sure where to start.

Thanks
 
Post info here. You never know someone may be able to answer your query on AAM.
 
asdfg - Thanks for the tip


In a nutshell - we bought our house in dec '99. We were first time buyers but as the house was 2nd hand we paid 4% stamp duty. My husband was posted abroad with his Irish company in July 2000 and we both moved away and are renting here. We have been renting our house out since but are now considering selling the house so that we can buy a bigger family home in Ireland. However we may not be moving home for another year or so.

We are wondering how to go about calculating the amount of capital gains tax we are liable for and if the fact that we were posted away on business with an irish company has any bearing on this fact. He only became employed by his employers swiss company last year - after they establisehed a swiss office. We have been declaring and paying tax on our rental income so that should be ok. I can't remember when we became non resident in Ireland (can check this out if it's important).

Also we have been told that even thought the new house will not be rented out the bank will treat it as a rental property with regards a mortgage as we are no longer resident in Ireland.
 
We are wondering how to go about calculating the amount of capital gains tax we are liable for and if the fact that we were posted away on business with an irish company has any bearing on this fact.

This is one which may/does require specialist tax advice.

This post contains information provided by staff at revenue (not always the most reliable source). It seems that you've gone past the four year absence allowed by Revenue for secondment reasons without impacting CGT or SD exemption.
I've never seen any Revenue documents in relation to this rule, infact that post is the only information I've come across on it to date, so not sure how the absence is considered once the four year threshold has been passed (Is it still considered in the CGT calculations or not).

Getting in touch with Revenue directly is one option, but if you can organise tax advice from an external expert first it may save you in the long run.
 
You will presumably be getting a solicitor to handle the house sale for you. Most solicitors will be able to get this information for you or employ a tax consultant on your behalf to advise you. This would seem to be the most efficient way of getting the help you need. Contact your solicitor and talk to them about your senario, if you don't have a solicitor get family or friends to recommend one.
 
Thanks for the link Satanta - it's good to have that info

Ramble - thanks for the suggestion of getting the solicitor to suggest the tax advisor.

Cheers!
 
Re: Capital Gains Tax query

Would your property in Ireland not be considered your Principal Private Residence as you have been only renting abroad? As long as you did not purchase a property abroad then your Principal Private Residence would not have changed. Gains accruing on the disposal of Principal Private Residence are exempt from Capital Gains Tax. There is full exemption only where the owner has occupied the house throughout his/her period of ownership. However the period of occupation is deemed to include certain periods of absence provided:

(a) that the individual has no other exempt residence at the time; and;

(b) the period of absence was both preceded by and followed by a period of occupation

It is not necessary for the periods of occupation to immediately precede and follow the periods of absence. It is enough that there was occupation at some time before and after absence. There is also a general rule whereby the last twelve months of ownership are included in the period of occupation as long as the owner was in occupation at some time during the period of ownership. The periods of absence which are deemed to be periods of occupation subject to (a) and (b) above are:

(a) any periods in which the owner was required by his/her employment to work wholly outside Ireland

(b) any period not exceeding four years in which the owner was required to work elsewhere in Ireland so that he could not occupy his private residence. Where such periods exceed four years, only four years are deemed to be periods of occupation.
 
I've never seen any Revenue documents in relation to this rule, infact that post is the only information I've come across on it to date

May I ask where you found that information Tenacious? I've flicked through some of the SD and CGT paperwork and have not found that information to date. Seems to spell it out a lot clearer than the link I provided above does.... and the details from Revenue (the e-mail recieved by a previous poster as linked above) do not seem to agree.
Revenue said:
It also states that any period of absence not exceeding 4 years where as a
condition of your employment you are obliged to work abroad.

 
Re: Capital Gains Tax query

Setanta,
I didn't get my information from Revenue. I have studied taxation as part of my accountancy exams. The four year rule only applies where you work elsewhere in Ireland and do not occupy your principal private residence.
 
(a) any periods in which the owner was required by his/her employment to work wholly outside Ireland

I would say that once you rent out the property wholly then it can no longer be classed as a PPR and so this get out clause wouldn't apply. I think the spirit of that clause would be to allow the family home to remain as a PPR whilst the main earner was posted abroad.
 
Re: Capital Gains Tax query

Your PPR only changes once you purchase another property. It is ok to rent it out while renting a property abroad.
 
Your PPR only changes once you purchase another property. It is ok to rent it out while renting a property abroad.

Not necessarily. Your PPR changes once you live somewhere else full time. I guess technically that clause could hold water until Revenue take a test case against someone and I suppose they're not so concerned with people breaking the spirit of the law.
 
Your PPR only changes once you purchase another property. It is ok to rent it out while renting a property abroad.

Again, this goes against a lot of what Revenue says.

I'm not questioning your information, and it's great that someone with some experience to give input here, but is there anywhere (if it's tax law then I'd assume it must be publically documented - legislative texts or whatever) we can confirm this and have in writing exactly what the details are?
 
Re: Capital Gains Tax query

Found this article in the Sunday Business Post archives. Hope this helps.

Principal Private Residence Exemption
A gain accruing to an individual on the disposal of a main residence dwelling is exempt from taxation, provided the individual occupied or is deemed to have occupied the residence throughout the period of ownership, with the exception of the last 12 months.
Where the individual did not occupy the residence throughout the ownership period, only part of the gain represented by the occupation part of the ownership period is exempt. In apportioning the gain, the last 12 months are taken as part of the total ownership period.
An individual who was obliged to live abroad or elsewhere for employment reasons may be treated as having lived in the residence during the period of absence if he lived in the residence before and after that period.
EXAMPLE
On January 1, 1993 X, a single person, bought an apartment in Ballsbridge in Dublin for £40,000.
She lived in the apartment until April 1, 1993 when she took up employment in the United States for one year and Canada for another year. During her time abroad, the apartment was occupied rent-free by her younger sister.
She returned to the apartment on May 5, 1995 and lived there until June 1, 1995 when she was required by her employer to move to Cork for three years.
She returned to the apartment on June 10, 1998 and lived there until May 31, 1999.
She rented the apartment from June 1, 1999 to 31 May 31, 2000.
She sold the apartment on June 1, 2000 for £200,000.
The potential gain is:
Proceeds (2000-01) £200,000
Cost £40,000 indexed at 1.186 (1992-93) £47,440
Gain £152,560
However, even though she lived in the apartment for less than 14 months, the entire gain is exempt, as she is treated as having occupied the apartment throughout the ownership period.
Notes
1. Had she not resided in the apartment before and after each period of absence, tax would arise on the entire gain.
2. If the period of absence from the apartment due to her employment conditions had exceeded four years, relief would be restricted to four years. In this example, the period in Cork (three years) is not therefore restricted.
If the residence was used partly for business purposes, only the residential part of the gain is exempt.
Up to one acre of adjoining grounds may be included as part of the residence. If part of the grounds is occupied with the residence, and part is not, the part most suitable for enjoyment with the residence is deemed to be part of the residence.
TIPS
1. Residence does not include a bungalow built some distance from the main dwelling but may include a caretaker's lodge of a large dwelling.
2. Residence does include an adjoining self-contained flat even if occupied by children or guests of the family.
3. Land or buildings physically separated from the house (for example, a separate lock-up garage) may be included if disposed of with the house.
4. Where part of the garden or grounds is disposed of, but the house is retained, exemption is available if the total area of land occupied with the house is not more than one acre.
Exemption from taxation would not be given to an individual selling half an acre from a 2.5 acre garden, but would be given to the extent of one quarter of an acre in the case of an individual selling half an acre from a 1.25 acre garden.
5. Exemption is allowed if during a period of absence abroad for employment reasons the residence was occupied rent-free by a relative of the claimant for the purpose of security or maintaining it in a habitable condition.
6. When an individual acquires land and has a house built on it, if the house is completed within a year of the date of acquisition and occupied as his only or main residence on completion, the period from the date of the acquisition of the land to the physical occupation of the house may be regarded as part of the period of occupation as main residence for exemption purposes.
7. A gain on the disposal of a residence which is trust property is exempt if throughout the ownership period the residence was occupied by a beneficiary of the trust entitled to occupy it.
8. This exemption also applies to the disposal of a residence occupied as his sole residence by a dependent relative of the individual but an individual may only claim exemption on the disposal of one dependent relative's residence at any one time.
If a husband and wife each have a dependent relative, each can get a separate exemption for his or her dependent relative. This means a husband and wife can potentially get three principal private residence exemptions.
TRAPS
1. The exemption does not apply to adjoining land which, although in the same ownership, was never incorporated in the garden.
2. If a dwelling house is sold, and part of the original garden is retained and later sold separately, the exemption only applies to the first disposal.
3. If and individual has two residences, he gets only one main residence exemption. To maximise relief, he should claim exemption for the more valuable residence. He can get exemption for the second residence, however, if he has a dependent relative residing in it.
4. This exemption does not apply, however, where the residence was acquired (mainly) with a view to resale at a profit.
5. To the extent that the gain on the disposal of a residence is due to its development potential, the gain is taxed as a disposal of development land (with no allowance for indexation except for the current use element of the gain).
 
My husband was posted abroad with his Irish company in July 2000 and we both moved away and are renting here. We have been renting our house out since but are now considering selling the house so that we can buy a bigger family home in Ireland. However we may not be moving home for another year or so.

We are wondering how to go about calculating the amount of capital gains tax we are liable for and if the fact that we were posted away on business with an irish company has any bearing on this fact. He only became employed by his employers swiss company last year - after they establisehed a swiss office.

I can't remember when we became non resident in Ireland (can check this out if it's important).

An individual who was obliged to live abroad or elsewhere for employment reasons may be treated as having lived in the residence during the period of absence if he lived in the residence before and after that period.
EXAMPLE
1. Had she not resided in the apartment before and after each period of absence, tax would arise on the entire gain.

If the residence was used partly for business purposes, only the residential part of the gain is exempt.

5. Exemption is allowed if during a period of absence abroad for employment reasons the residence was occupied rent-free by a relative of the claimant for the purpose of security or maintaining it in a habitable condition.

Ok my reading of this is that the OP will be liable for CGT for the full term.

1. The OP doesn't appear to have any intention of returning to live in the property - must live in the property before AND after the period away.

2. This is more of a lateral point but the property can't be used for for commercial purposes, if it is then the period during which it was used for commercial purposes is liable. Renting the place out counts as a commercial purpose in my books. This is enforced by the fact that the example explicitly says that where a relative stayed rent free during the period of absence then you are ok for cgt.

3. The OP is no longer seconded abroad by an Irish company, he has now taken up full time employment with a Swiss company (since last year).
 
1. The OP doesn't appear to have any intention of returning to live in the property - must live in the property before AND after the period away.

They are however returning to ireland. Could they move back into the property on returning to ireland and then sell. Is there a minimum period that they must reside in the house on their return.

Can the subject matter be changed to reflect the details of the tread more accurately in order to make searches easier.
 
They are however returning to ireland. Could they move back into the property on returning to ireland and then sell. Is there a minimum period that they must reside in the house on their return.

Can the subject matter be changed to reflect the details of the tread more accurately in order to make searches easier.

I think my third point makes that a non runner. "I believe" the idea of the temporary secondment clause is explicitly that, to cater for temporary changes in employment. Once permanent employment was taken up with a foreign company then you can no longer avail of it. Ideally the OP should have sold up their Irish property just prior to taking up full time employment, having moved in for a nominal week or 2.

Just to clarify, I'm not a tax expert. It seems to me that a lot of loopholes in the tax laws are open to interpretation, the stronger your argument the more likely you are to avail of a certain break. I'd be interested to know if Tenacious agrees with my interpretation of this scenario given his background. Would probably make a decent exam question.

The title does need a changing.
 
Re: Capital Gains Tax query

The fact that the OP rented out the home in Ireland while abroad means that full exemption to CGT is restricted by the amount of time the OP did not occupy the house. Had OP allowed a dependent relative to occupy the house (as his/her sole private residence throughout the period OP was required by their employment to work wholly outside Ireland) free of charge full exemption to CGT could have been preserved. Then again OP would have no rental income that may well prove to be greater than the CGT payable on disposal of the property.

Where occupation has been only for part of the period of ownership the exempt part of the gain is the proportion is given by the formula :


Period of occupation post 6th April 1974 * chargeable gain
Total period of ownership post 6th April 1974





Any period before 6th April 1974 is ignored.

The last twelve months of ownership of the property are included in the period of occupation as long as the owner was in occupation at some time during this period of ownership, even if this is just one night. It doesn't matter that the house was rented out during the last twelve months as long as the owner stayed at least one night.

In this case where full exemption to CGT is not available then partial relief will apply to reduce the liability of any chargeable gain arising on the disposal.


Revenue's leaflet on CGT (including Indexation tables)
http://www.revenue.ie/leaflets/cgt1.pdf
 
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