WDB Porter vs. Inland Revenue

In November 2002, the Inland Revenue raised an enquiry into my 2000/2001 tax return. They disputed my treatment of a payment made from the J.P.Morgan Stock Bonus Plan in February 2001, years after I have been made redundant in October 1998. As part of my redundancy package, the bank had "allowed me to keep my shares", which would normally have been lost when I left the firm. This clearly should attract "S148" treatment (taxation of payments made in consideration of the ending of employment) under the Income and Taxes Act 1988, as opposed to "S19" (taxation of payments "from" the employment). S148 was favourable to me as I received a deduction because half of my career had been overseas.

After over four years of Revenue obstinacy and several bookshelf-inches of correspondence, I was finally able to force the Revenue to see the light in front of the Special Commissioners. An unbelievable waste of public money and my time (this site shows the effects). Thank you Gordon Brown and his "enforcement policy".

Table of links: