CGT as gift to connected person but PPR applies. Still reportable though in view of the value of the properties. Father will have incurred legal costs in transferring title to son. Son acquires property at date of gift at market value. No IHT if father lives 7 years and no SDLT if no mortgages transferred.
Very risky strategy as father now has gifted £10m from his estate and son's estate has now increased by £10m BUT father has no recourse on the £10m and the other £5m is still son's. Son could kick his father out and keep both properties.
Thank you. they haven't actually set the trust up yet so should I flag that when drafting the trust deed they need to ensure it is worded such that his company can charge expenses for managing the property. In which case should the company be named as a trustee rather than him personally? And what about the fact that his wife owns half of the property. She is also a director of his company but doesn't draw any salary or dividends.
So what is it for a single director company not wanting to pay employers NIC? I cant see that a new secondary threshold for Class 1 NIC has been announced - just a new primary threshold. Normally it is the secondary threshold that dictates the optimum salary as this means the director can continue to qualify for state pension payments but not pay any NIC.
My answers
Thank you this is very helpful. As usual I suspect I have only been given half the picture by the client!
Cant you login to your agent account and request a repayment that way?
Also agent helpline still works, albeit as slow as ever
This is the only reference I can find in the IHT manuals
https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm10082
CGT as gift to connected person but PPR applies. Still reportable though in view of the value of the properties. Father will have incurred legal costs in transferring title to son. Son acquires property at date of gift at market value. No IHT if father lives 7 years and no SDLT if no mortgages transferred.
Very risky strategy as father now has gifted £10m from his estate and son's estate has now increased by £10m BUT father has no recourse on the £10m and the other £5m is still son's. Son could kick his father out and keep both properties.
Thank you. they haven't actually set the trust up yet so should I flag that when drafting the trust deed they need to ensure it is worded such that his company can charge expenses for managing the property. In which case should the company be named as a trustee rather than him personally? And what about the fact that his wife owns half of the property. She is also a director of his company but doesn't draw any salary or dividends.
Got it so £9100 is optimum salary for ltd co with one salaried director for 2022/23.
If on other hand employer qualified for Employment Allowance then optimum salary would be £12,570. Simples
Got it so £9100 is optimum salary for ltd co with one salaried director for 2022/23.
If on other hand employer qualified for Employment Allowance then optimum salary would be £12,570. Simples
https://www.thefriendlyaccountants.co.uk/best-combination-of-dividends-a...
Thank you very helpful
So what is it for a single director company not wanting to pay employers NIC? I cant see that a new secondary threshold for Class 1 NIC has been announced - just a new primary threshold. Normally it is the secondary threshold that dictates the optimum salary as this means the director can continue to qualify for state pension payments but not pay any NIC.