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 […]
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 […]
Company Purchase Of Own Shares: Exit With Care!
A company purchase of own shares (CPOS) can be a useful ‘exit’ strategy for shareholders in the right circumstances. This article looks at the purchase by an unquoted trading company of its own shares from an individual shareholder of a family or owner-managed company. As a general rule, when the company buys back its own […]
Company Purchase Of Own Shares: Exit With Care!
A company purchase of own shares (CPOS) can be a useful ‘exit’ strategy for shareholders in the right circumstances. This article looks at the purchase by an unquoted trading company of its own shares from an individual shareholder of a family or owner-managed company. As a general rule, when the company buys back its own […]
Private Residence Relief: HMRC’s ‘Off-Plan’ Arguments Off Target!
A private residence relief case involving an individual’s delay moving into a dwelling whilst it was being built. The extent to which capital gains tax (CGT) principal private residence (PPR) relief is available on the disposal of an individual’s only or main residence is straightforward to establish in most cases. However, differences in interpreting the […]
Private Residence Relief: When ‘Quality Trumped Quantity’!
Most individuals who dispose of their dwelling-house expect that any capital gain will be subject to private residence relief. Many of them are correct, but unfortunately some are left disappointed. Private residence relief broadly applies to gains accruing to individuals on the disposal of (or of an interest in) all or part of a dwelling […]
Loans To Traders: They Think It’s All Over…
An individual who makes a loan to a company they own will probably expect to obtain tax relief if the loan subsequently has to be written off. Capital gains tax relief on the loan write-off is potentially available if certain conditions are satisfied. One such condition is that the loan has become irrecoverable. This might […]
Penalties For Tax Return Errors – All Is Not Lost!
The penalty rules for errors in tax returns etc potentially apply if a tax return contains an inaccuracy that results in a tax liability being understated. In addition, a penalty can apply if an error gives rise to a false or inflated loss (FA 2007, Sch 24, para 1). Errors involving losses The amount of […]