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My client holds all of the voting A shares of an unquoted close company. His wife has a small holding of non-voting B shares.
The proposal is to give three votes to each A share (instead of one) and two votes to each B share (instead of none). My client will then turn about 5% of his A shares into C shares (with one vote each) and about 20% into D shares, which will have no votes. My client will then control 92% of the voting rights. That would seem to be an alteration within IHTA 1984, s 98(1)(b).
My client holds all of the voting A shares of an unquoted close company. His wife has a small holding of non-voting B shares.
The proposal is to give three votes to each A share (instead of one) and two votes to each B share (instead of none). My client will then turn about 5% of his A shares into C shares (with one vote each) and about 20% into D shares which will have no votes. My client will then control 92% of the voting rights. That would seem to be an alteration within IHTA 1984 s 98(1)(b).
Presumably the amount of the disposition is to be determined by comparing the original value of the A shares with their subsequent value aggregated with the value of the C and D shares. One is tempted to say that the value both before and after will be virtually...
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