Member Since: 12th Jun 2014
19th Jun 2020
17,972 years! I'm sure i will be retired by then.
8th Jun 2020
[Edit] Assumes the loan notes are QCBs
The election to which you refer is under s169R TCGA I assume. If this is the case then the election disapplies the no disposal rule by electing for the reorganisation which gave rise to the loan notes to be regarded as a disposal. This allows business asset disposal relief (formerly known as entrepreneurs' relief) to be claimed on the gain on the disposal of the shares.
If the election is made then there is a dry tax charge but it does bank the BADR(aka ER).
Absent the election, the disposal of the loan notes on their realisation would crystallise the latent gain in the loan notes (the gain rolled into the loan notes on the reorganisation). BADR (aka ER) is not available on a disposal of loan notes so the gain arising at that point would not be sheltered by it.
Obviously, if the election is made then tax is due at that point and if the loan notes are never redeemed (company gets into difficulty) the client will have paid tax for nothing. The trade off is that, if the election is not made, then more tax will be payable later assuming the redemption happens.
4th Jun 2020
Reopening threads like these makes me realise how many of the old posters have now gone.
The band is the relatively short lived Goodbye Mr MacKenzie. Can't think of the name of the track. Didn't realise they had had a reunion tour.
2nd Jun 2020
The incidental costs of raising loan finance for a business or investment company have been allowable for ages. I recall the provision back in ICTA 1970 but can't remember where it was. It did become s77 ICTA 1988 then got split for income tax purposes and corporation tax purposes (ITTOIA and CTA 2009).
1st Jun 2020
Somehow reminded of a cross between Little Britain and Yes Minister! Equivocation and plausible deniability v the truth!
1st Jun 2020
From our house in about 1/4 of an acre the non-natural noise is the occasional motor vehicle in the lane outside or neighbour working in next door farmyard. Apart from that it is just bird song mainly - those blackbirds can be noisy!
27th May 2020
I think the point is that diabetics are at risk of developing ketoacidosis (which is very serious if untreated) with this virus as well as the general risk of an inflammatory response in the lungs which other folk, asthmatic or not, are also in danger of getting.
26th May 2020
Just a query if you don't mind. Have you considered whether s1035(3) CTA 2010 may apply to increase the length of ownership or did the parents literally acquire their shares from scratch 4 and 3 years ago?
22nd May 2020
If she purchased the shares in the company what choice did she have - it is the company that is registered for VAT, not the shareholders!
12th May 2020
Tax Dragon wrote:
It's a company.
Yes, and the Croner-i extract was from the commentary on "Companies carrying on mutual business" so I don't quite see the relevance of your comment although you are, of course, correct - it is indeed a company!