Andrew Goldstone and Charlie Sosna (Mishcon de Reya) review recent private client tax developments that matter.
Moore and Castledine: entrepreneurs’ relief
Two recent cases demonstrate the care required to ensure that taxpayers structure their affairs correctly to benefit from entrepreneurs’ relief (ER).
In Moore v HMRC [2016] UKFTT 115 (TC) (reported in Tax Journal 4 March 2016) the FTT rejected Mr Moore’s appeal to claim ER. Mr Moore had been a 30% shareholder of a company but decided to leave the business in 2008 after a disagreement as to the future direction of the company. There were a series of key dates and the crux of the matter was whether Mr Moore was a director at the time he disposed of his shares. In February 2009 the company agreed to purchase Mr Moore’s shares. However...
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Andrew Goldstone and Charlie Sosna (Mishcon de Reya) review recent private client tax developments that matter.
Moore and Castledine: entrepreneurs’ relief
Two recent cases demonstrate the care required to ensure that taxpayers structure their affairs correctly to benefit from entrepreneurs’ relief (ER).
In Moore v HMRC [2016] UKFTT 115 (TC) (reported in Tax Journal 4 March 2016) the FTT rejected Mr Moore’s appeal to claim ER. Mr Moore had been a 30% shareholder of a company but decided to leave the business in 2008 after a disagreement as to the future direction of the company. There were a series of key dates and the crux of the matter was whether Mr Moore was a director at the time he disposed of his shares. In February 2009 the company agreed to purchase Mr Moore’s shares. However...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
