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Where Taxpayers and Advisers Meet

Search found 48 matches

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by Milbo
Thu Dec 12, 2013 11:20 am
Forum: International Tax
Topic: EFRB loan to Eire resident company
Replies: 0
Views: 387

EFRB loan to Eire resident company

A substantial loan has been made by the Director's UK EFRB to an Eire resident company. The purpose of the loan is to assist with the purchase a property in the UK which is let out on a commercial basis to a UK company. Loan interest is paid quarterly to the EFRB by the Irish company. Does anyone kn...
by Milbo
Wed Jun 12, 2013 11:39 am
Forum: Tax Investigations and Enquiries
Topic: Visit by Data Handling Experts
Replies: 6
Views: 1791

Re: Visit by Data Handling Experts

No problem wamstax, I appreciated your offer to discuss the visit.
by Milbo
Wed Jun 12, 2013 10:46 am
Forum: Tax Investigations and Enquiries
Topic: Visit by Data Handling Experts
Replies: 6
Views: 1791

Re: Visit by Data Handling Experts

Thanks all, the visit took place last week. In advance of the visit I was able to agree with HMRC, via e-mail therefore documented, the information which they were going to extract from the systems. HMRC have not at any time suggested that there are unrecorded takings, just confusion how the client ...
by Milbo
Fri May 31, 2013 10:28 am
Forum: Tax Investigations and Enquiries
Topic: Visit by Data Handling Experts
Replies: 6
Views: 1791

Visit by Data Handling Experts

I have an on-going enquiry into a convenience store. HMRC have examined the client's analysed records and produced revised takings figures which we disputed and found to be incorrect. They have since examined a sample of the till rolls and now want to visit the client's premises with two Data Handli...
by Milbo
Wed May 15, 2013 11:13 am
Forum: General
Topic: Samadian v HMRC TC 2523
Replies: 0
Views: 3358

Samadian v HMRC TC 2523

The tribunal decision was released on 28 January 2013 and Dr Samadian had 56 days to appeal.

Does anyone know whether an appeal was submitted?

Thanks,

Milbo
by Milbo
Mon Apr 15, 2013 9:58 am
Forum: Capital Gains Tax, CGT
Topic: Employment-related securities or not!
Replies: 4
Views: 991

Re: Employment-related securities or not!

Thanks Loza for your comprehensive reply.

Much appreciated.
by Milbo
Fri Apr 12, 2013 10:41 am
Forum: Capital Gains Tax, CGT
Topic: Employment-related securities or not!
Replies: 4
Views: 991

Re: Employment-related securities or not!

Hi Loza, Due to family circumstances, Friend B did not want to be associated with a new company and asked Friend A to be the sole shareholder and director in the new venture. He accepted and is being paid accordingly. The friends have now agreed that A should transfer his shares to B at zero cost. F...
by Milbo
Thu Apr 11, 2013 6:36 pm
Forum: Capital Gains Tax, CGT
Topic: Employment-related securities or not!
Replies: 4
Views: 991

Employment-related securities or not!

Friend A (sole director) wants to give his 100% shareholding in his wholly owned trading company to Friend B, a former employee of the company (he left approx. 6 months ago in 2012/13). The value of the shares is £50,000 and Friend A can make a hold-over relief claim thus ensuring that he does not h...
by Milbo
Thu Mar 28, 2013 2:36 pm
Forum: Capital Gains Tax, CGT
Topic: Entrepreneurs Relief - Employee or Official
Replies: 9
Views: 1051

Re: Entrepreneurs Relief - Employee or Official

The business is a Health Centre Pharmacy and the shareholders are the Doctors (who practice nearby) and a Pharmacist who has another independent Pharmacy again nearby. The individual selling the shares is one of the Doctors. No remuneration has been taken whilst the pharmacy becomes established. Wor...
by Milbo
Thu Mar 28, 2013 1:00 pm
Forum: Capital Gains Tax, CGT
Topic: Entrepreneurs Relief - Employee or Official
Replies: 9
Views: 1051

Re: Entrepreneurs Relief - Employee or Official

Thanks all.

The P46 was signed over 12 months ago but has not been sent to HMRC otherwise we would be able to prove the employee status even though no remuneration has been paid.

Are HMRC likely to accept a signed P46 as employee status when claiming ER?

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