The High Court in Chalcot Training Ltd considered whether a payment into an EBT is remuneration or a distribution.
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