Member Since: 30th Jan 2003
18th Jan 2019
yes, but at 0.000000001%
5th Dec 2018
I understand they have accepted some of his arguments.
Also see the article example with a large tax difference and the reasons (eg personal allowance).
5th Dec 2018
See article Tim Good's article:
21st Nov 2018
But, unlike the case link, with EBTs there are four transactions to consider,
not one? The taxpayer’s bad choice of using a tax scheme, the company settling funds, the trustees deciding to make a loan and the taxpayer accepting the terms of that loan.
Given the trustees hold a valuable asset for beneficiaries, which may include minors, surely the trustees would need to be a willing party to any claim for set aside, to protect their position?
If the transactions have not yet caused unexpected tax (eg HMRC out of time to go after employer, taxpayer doesn’t wish to settle) and the loan charge is a new tax that only hits if the loan is not repaid, where is the mistake to be set aside?
8th Nov 2018
Appealing the gift to UKIP tax treatment seemed hopeless, even if the grounds are amusingly ironic.
For the later donations to the referendum campaign, I wonder if they’ll try arguing s10 IHTA (with s268), on the basis that the intention was effectively spending on leaflets and adverts?
12th Sep 2018
Worth getting a lawyer to review your engagement letter, so there are no implied duties of care. But useful terms I’ve seen in such cirmumstances (to make it clear who is your client) are:
“If your own client wishes to rely on our advice they should engage us for the work themselves via a
separate engagement letter agreed with us and signed by them.
We will need to see your underlying client identification for work
relating to your clients before we begin the work.
Payment of our fees by you is not linked to how you may recharge these to your clients nor any delay
in your own fees being paid by your client. If our fees remain outstanding in relation to one of your clients, you agree that we may cease work relating to your other clients until those fees are paid.”
9th Sep 2018
Get some proper tax and legal advice. You’re in danger of making mistakes, for which you may be personally liable, if you rely on the product provider, HMRC and forums.
13th Aug 2018
I find a bespoke approach, similar to Matrix, also works well for my clients. Some had paid, some needed a nudge and overall a useful opportunity to catch up with client activity and the 2018 tax return progress.
11th Aug 2018
At a previous firm it was suggested to dump troublesome clients with the lie:
“we’ve identified a potential conflict of interest and must cease to act”
If the client response is “what potential conflict of interest?”...
...“Because it may be a conflict of interest, we cannot inform you what it is”
7th Aug 2018
Which sounds like the loan (an asset of the trust) has been written off in favour of your client, so no 2019 loan charge but possibly taxable at the point of write off?