Taxation of Property Transactions : A Critical Analysis of Section 67 of the Income Tax Act 1976

Section 67 of the Income Tax Act 1976 taxes as income certain gains on the sale of land that would ordinarily be classed as capital. Several proposals were made to repeal the section or severely to limit its effect. The article argues that the section contains a number of flaws, though none that is fundamental. On the assumption that the section is to be maintained, several remedial measures are proposed to overcome the perceived shortcomings of the section. The provisions of the former section 67 remain in the Income Tax Act 2007