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.
McQuillan: shares with no dividend excluded from ordinary share capital
In McQuillan v HMRC [2016] UK FTT 305 (TC) (reported in Tax Journal 20 May) the two appellants each held 33 of the 100 original issued shares of a company. Invest Northern Ireland offered grants to the company on condition that a loan of £30 000 from the two other directors was converted to shares. As a result the company issued to the directors 30 000 redeemable non-voting ordinary shares with no rights to a dividend.
The appellants sold their shares in 2010. They expected to benefit from entrepreneurs’ relief thinking they held more than the required 5%...
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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.
McQuillan: shares with no dividend excluded from ordinary share capital
In McQuillan v HMRC [2016] UK FTT 305 (TC) (reported in Tax Journal 20 May) the two appellants each held 33 of the 100 original issued shares of a company. Invest Northern Ireland offered grants to the company on condition that a loan of £30 000 from the two other directors was converted to shares. As a result the company issued to the directors 30 000 redeemable non-voting ordinary shares with no rights to a dividend.
The appellants sold their shares in 2010. They expected to benefit from entrepreneurs’ relief thinking they held more than the required 5%...
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:
