28 Jun 2006
COMMISSIONER OF INLAND REVENUE v. ELLIOT, STEWART WILLIAM GEORGE
- Citation
- COMMISSIONER OF INLAND REVENUE v. ELLIOT, STEWART WILLIAM GEORGE
- Court
- Court of First Instance
- Case number
- HCIA12/2005
Portion of the US$11,000,000 attributable to cancellation of the 5,000,000 incentive units is taxable only to the extent it represents the value of the inducement; the Board erred in treating the entire portion attributed to the 5M Units as taxable and in fixing a 50% apportionment on the facts found. The matter is factual and best remitted to the Board under s.69(5) to determine the taxable proportion representing the inducement.