Minutes of meeting with Capital Taxes Office, Inland Revenue on 11 October 1994

Note of a meeting between the Share Scheme Lawyers Group and Mr. Perfect of the Inland Revenue, Capital Taxes Office on 11 October 1994 regarding issues raised in the group’s paper of 22 October 1991 on inheritance tax and capital gains tax issues relevant to Employee Share Ownership Plans. Mr. Perfect had responded to the issues raised in the 22 October 1991 note in a letter of 4 May 1993. The main issues discussed were:

  • Section 86 Inheritance Tax Act – the circumstances in which an application of settled property should be regarded as for the benefit of persons other than permitted beneficiaries;
  • Sections 65 and 67 Inheritance Tax Act 1984 – Occasions which may potentially attract an inheritance tax charge;
  • Section 65 Inheritance Tax Act 1984 – Occasions which may potentially attract an inheritance tax charge to a non-s.86 ESOP;
  • Section 13 Inheritance Tax Act 1984 – Close companies; and
  • Section 15 Inheritance Tax Act 1984 – Waiver of dividends.
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Keywords: CGT, EBT, Inheritance tax
Categories: Document archive, Trusts