Alphabet shares are dead…long live alphabet shares!
Amongst the detail of the Budget 2018 were some tweaks to the entrepreneurs’ relief legislation, which led to a lot of speculation and commentary. Did the proposed change to the definition of a ‘personal company’ (in TCGA 1992, s 169S(3)) mean the end to alphabet shares? To set some context first, ‘alphabet shares’ is the […]
Alphabet shares are dead…long live alphabet shares!
Amongst the detail of the Budget 2018 were some tweaks to the entrepreneurs’ relief legislation, which led to a lot of speculation and commentary. Did the proposed change to the definition of a ‘personal company’ (in TCGA 1992, s 169S(3)) mean the end to alphabet shares? To set some context first, ‘alphabet shares’ is the […]
Are You Winding Me Up?
When HM Revenue and Customs (HMRC) encounters an arrangement that it regards as tax avoidance (or ‘unacceptable’ tax planning), the government will often seek to block it by introducing targeted anti-avoidance legislation. Rising from the ashes? For example, a targeted anti-avoidance rule (TAAR) was introduced (in Finance Act 2016) to prevent ‘phoenixism’. In very broad […]
Are You Winding Me Up?
When HM Revenue and Customs (HMRC) encounters an arrangement that it regards as tax avoidance (or ‘unacceptable’ tax planning), the government will often seek to block it by introducing targeted anti-avoidance legislation. Rising from the ashes? For example, a targeted anti-avoidance rule (TAAR) was introduced (in Finance Act 2016) to prevent ‘phoenixism’. In very broad […]
Tax Planning Nobody Will Rush To Try!
“In this world nothing can be said to be certain, except death and taxes.” This is a well-known quotation attributed to Benjamin Franklin. To prefer not to think about one’s own mortality is normal and natural. However, tax is a consideration both during lifetime and on death. It is therefore prudent to consider steps to […]
Property Rental Expenses: Your Guess Is As Good As Mine!
Keeping full and proper records of property rental business expenses is an important task for landlords. For example, HM Revenue and Customs (HMRC) could seek to disallow such expenses if there is insufficient evidence that the expenditure has been incurred, and may impose penalties for record keeping failures. Property rental business owners are subject to […]
Making Family Trading Company Investments IHT Efficient
Many family and owner-managed trading company owners invest in their businesses through a combination of acquiring shares and making cash loans. The company might use the funds for the same business purpose, but the inheritance tax (IHT) implications of the shares and cash loans will often differ, depending on the availability of business property relief […]
POAT: Out Of The Frying Pan Into The Fire? Part 2
Some possible exceptions to the pre-owned assets income tax charge, as it applies to land and property. The pre-owned assets tax (POAT) is an income tax charge that can be an unexpected and unpleasant surprise for some individuals. Fortunately, the scope of POAT is restricted by a number of excluded transactions and exemptions from the […]
POAT: Out Of The Frying Pan Into The Fire? Part 2
Some possible exceptions to the pre-owned assets income tax charge, as it applies to land and property. The pre-owned assets tax (POAT) is an income tax charge that can be an unexpected and unpleasant surprise for some individuals. Fortunately, the scope of POAT is restricted by a number of excluded transactions and exemptions from the […]