Tax and trust law issues

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15/01/2016Comments on Manuals review
Comments on the draft ETASSUM manuals submitted by SPL (including additional SAYE comments from January 2016).
tags: EMI Manuals review Qualifying companies SAYE SAYE Guidance Schedule 4 CSOP tax-advantaged share plan manual
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26/11/2015Murray Case
HMRC comment on share plan implications of Murray case.
tags: Court of Session Murray Case cash payments deferred bonus awards employee trusts
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29/01/2015HMRC - Minutes of Annual Technical Meeting - 29 January 2015
tags: CSOP CSOP option certificates Capital Gains Clawback Death Demerger Disguised Remuneration Employee shareholder shares Guidance Malus Market Value Substitution Rule Market value of listed shares Money's worth charge Non-Uk company reorganisations Option adjustments Overseas equivalent legislation Paragraph 43(4) Parallel options Public offer exclusions Purpose test Qualifying replacement EMI option Reporting Roll-over differences SAYE SIP Share scheme manuals non-UK company reorganisatoin arrangement non-resident issues partnership share deductions reorganisations of share capital restricted stock units restrictions attaching to shares small companies substantial proportion tax-advantaged schemes tax-free earnings
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09/07/2014Questions and discussion items for meeting between HMRC and Tax Committee of Share Plan Lawyers on 9 July 2014
Subjects for discussion include:

General:
1. Clawback and malus
2. HMRC guidance for tax-favoured plans
3. Set up costs for tax-favoured plans
4. Market value
5. 20 day Rule
6. Questions on Annual Rreturns, both tax-favoured and non-tax favoured
7. SIP restriction/forfeiture question
Manual-related questions:
- SIP Manual
- SAYE Manual
- CSOP Manual
- EMI Manual
tags: 20 Day Rule CGT CSOP Clawback Death Dividend income EMI FSA Financial Reporting Council Forfeiture Malus PAYE Qualifying employee Retirement SAYE SIP Self-certification
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05/06/2014HMRC Comments on manuals
Email from Anne H Smith at HMRC giving responses to HMRC comments on HMRC manuals. In particular specific queries relating to:
- malus/clawback
- section 409A
- Ordinary Residence
- EMI
tags: CSOP EMI Financial Reporting Council Forfeiture Malus Ordinary residence Pre-emption rights Residency test SAYE SIP Section 409A
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