HMRC meetings
- 05/12/2002Agenda for meeting with Inland Revenue Employee Shares Scheme Unit on 5 December 2002
Agenda for meeting with Inland Revenue Employee Shares Scheme Unit on 5 December 2002.
Download - (requires membership login) - 05/12/2002Minutes of a meeting with the Inland Revenue on 5 December 2002
Minutes of a meeting with the Inland Revenue on 5 December 2002. Considers:
- how the surrender of options will affect individual limits under EMI schemes;
- when a change to a company's articles of association will be considered a change to a key feature of a SIP;
- restrictions on the types of shares which can be used in connection with a SIP;
- how the rules for SIPs on rights issues will apply where a company has preference shares;
- whether invitations to participate in a SIP are made on a rolling basis and how to treat new joiners;
- whether it is possible to have different participating companies in a SIP for different parts of the plan (eg for free shares but not partnership shares);
- electronic communications in relation to SIPs;
- non-UK transactions which are equivalent to a scheme of arrangement;
- exclusion of the Contract (Rights of Third Parties) Act in approved schemes;
- whether an option scheme with a cash alternative provides a "right to acquire" shares;
- Mansworth v Jelley.
- 06/12/2001Agenda for Meeting with Inland Revenue on 6 December 2001
Agenda for Meeting with Inland Revenue on 6 December 2001.
Download - (requires membership login) - 28/11/2000Note of a meeting with the Inland Revenue on 28 November 2000
Note of a meeting with the Inland Revenue on 28 November 2000. Considers:
- whether the number of partnership shares bought under a Share Incentive Plan at the end of an accumulation period can be limited to the number which can be bought with the money put in;
- the circumstances in which matching shares could be subject to forfeiture;
- the taxation of dividends on unallocated shares in a Share Incentive Plan;
- the difficulty of assessing national insurance cotnributions and whether a flat rate would be considered;
- discussion of a large number of issues on EMI schemes;
- stamp duty on SIPs, QUESTs and SAYE
- QUESTs and schemes of arrangement;
- American Depositary Receipts and Global Depositary Receipts and CSOPs.
- 22/02/2000Note of a meeting with the Inland Revenue on 22 February 2000
Note of a meeting with the Inland Revenue on 22 February 2000. Considers:
- Status of approval of letters to optionholders on takeover etc;
- Option rollover - section 136 ICTA 1988
- Definition of "scheme shares" - US limited liability companies and American Depositary Receipts;
- Meaning of "ordinary shares" - section 832 ICTA 1988 - shares with no right to receive any dividend;
- Restrictions in a Company's articles of association and their impact for the purposes of being able to establish an approved CSOP;
- Transfer Pricing;
- Share Option Schemes - amendments to terms of share option - Application of Eurocopy and Reed Internationalcases;
- Income tax charge under section 135 ICTA 1988;
- Options granted at a discount - application of section 29(2) TCGA 1992;
- Advance payment for the grant of an option;
- Determination of "readily convertible assets" and meaning of "trading arrangements";
- PAYE and National Insurance - Cash Cancellation payments;
- National Insurance Regulations - rollover of options;
- Amendments to Section 165 TGCA 1992 - trusts;
- Limited Partnerships - acquisition of partneship capital - application of section 79 Finance Act 1972.
