Andrew Goldstone and Jeffrey Lee (Mishcon de Reya) review recent private client tax developments that matter, including the decisions in McQuillan, X-Wind Power, Mabbutt and Shah.
Thomas Dalby (Gabelle) answers a query on managing the retirement of a senior employee who holds company shares, as well as assets in an EBT.
Keith Gregory (NGM Tax Law) answers a query on how an EBT trustee wishing to provide loan finance in connection with a joint venture development company can avoid triggering a charge under the disguised remuneration rules
Thomas Dalby (Gabelle) answers a query on a client that acquired, and now wishes to dispose of, a company with a UK-resident EBT holding a number of shares
The Upper Tribunal has now handed down the eagerly awaited judgment in HMRC v Murray Group Holdings and others, better known as ‘the Rangers case’. Robert Waterson and Adam Craggs review the lessons from the decision, which resulted in a loss for HMRC in its campaign against EBTs that it is likely to appeal.
Jeremy Glover answers a query on an outstanding loan from a subtrust within an EBT
James Frampton comments on EBT loans and IHT complications
Purchasing a company that has implemented trust-based remuneration planning brings with it some technical and practical challenges. Jon Robinson and Chris Thomas offer guidance to buyers
Philip Fisher warns of potential challenges from HMRC to long accepted tax planning techniques involving dividends, following the decision by PA Holdings to withdraw its appeal to the Court of Appeal judgment.