Note of a meeting with the Inland Revenue on 8 September 1998

Note of a meeting with the Inland Revenue on 8 September 1998. Considers:

  • The application of Section 140C (now repealed) on management buyouts where employees were not employed by the company whose shares they were given.
  • Relationship between Section 140A and Section 162 (now repealed)
  • Whether a companys’ shares become readily convertible assets just because advisers have been consulted in relation to a possible listing.
  • Whether pre-emption provisions or the mere existence of an employee trust amounted to trading arrangements.
  • Application of 140D (now repealed but dealing with convertible shares) to situations where conversion was automatic.
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Keywords: Bad Leaver, EBT, Forfeiture, IPO, Leavers, PAYE, Pre-emption rights, Readily Convertible Asset
Categories: Document archive, HMRC meetings