Trusts
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- 26/11/2015Murray Case
HMRC comment on share plan implications of Murray case.
Download - (requires membership login) - 14/02/2014SPL submission to HMRC and HM Treasury regarding draft legislation on trusts for Finance Bill 2014
SPL submission from February 2014 regarding the draft legislation on tax incentives for employee ownership trusts for the Finance Bill 2014 published by HMRC and HM Treasury on 10 December 2013.
The draft legislation to which SPL's comments relate is attached to the end of the submission.
Download - (requires membership login) - 20/06/2013SPL submission dated 20 June 2013 commenting on revised draft of Inheritance Tax Manual
SPL submission dated 20 June 2013 commenting on revised draft of Inheritance Tax Manual, section 42900 onwards relating to employee benefit trusts which was circulated by HMRC in June 2013 prior to publication of the revised manual on 1 July 2013.
Included in the attached copy of the submission is:
- a covering email setting out preliminary SPL comments;
- a mark up of relevant sections of the draft Inheritance Tax Manual; and
- a copy of the Agenda and minutes of the SPL meeting with HMRC held on 11 November 2009.
Not included in the attached document but referred to in the response and available in the "Trusts" section of this Knowhow Archive are:
- SPL submission dated 22 October 1991 on inheritance tax and capital gains tax issues relevant to ESOPs;
- Letter from Capital Taxes Office dated 4 May 1993 responding to 1991 SPL paper on ESOPs; and
- Minutes of meeting with Capital Taxes Office, Inland Revenue on 11 October 1994.
- 19/06/2013Revised draft Inheritance Tax Manual, section 42900 onwards, relating to Employee benefit trusts
Revised draft of Inheritance Tax Manual, section 42900 onwards relating to Employee benefit trusts which was circulated by HMRC in June 2013 prior to publication of the revised manual on 1 July 2013
Download - (requires membership login) - 12/05/1995Note of conversation with CTO on 12 May 1995 regarding sections 86 and 72 of the Inheritance Tax Act
File note of a conversation with the Inland Revenue Capital Taxes Office in respect of section 86 Inheritance Tax Act 1984 and section 72(2)(c) Inheritance Tax Act 1984.
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