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The importance of a little known relief
KEVIN SLEVIN FTII, ATT takes a look at the capital gains tax problems which arise with contingent consideration.
KEVIN SLEVIN FTII, ATT illustrates the conflicts of interests that can arise when tax advisers advise both individual and corporate shareholders of a company. TO GET TO grips with the main point of this article, readers must imagine the following scenario. The article raises issues for the tax practitioner which have not received the attention they deserve. Potentially, the points arising from the example have far-reaching implications for all those advising individual and corporate shareholders of the same company.
KEVIN SLEVIN FTII, ATT, TEP explains why he is writing yet another article about taper relief, when it is supposed to be so simple.
THERE IS LITTLE doubt in my mind that if I state at this point just what this article is about, many readers will immediately form the view, almost certainly an incorrect view, that the subject matter is of little interest to them. So I will simply say that if you advise on capital gains tax and you do not read this article, you could be making a very big mistake.
KEVIN SLEVIN FTII, ATT, TEP explains the latest changes to the meaning of 'security' for taper relief purposes.
THIS SHORT ARTICLE follows a number of earlier articles in Taxation magazine this year on the meaning of 'security' for taper relief purposes [see previous]. Regular readers will not need a summary of the saga up to this point, and most will have seen the Inland Revenue's press release dated 15 November 2001, which announced the intention to introduce new legislation defining 'security' for taper relief purposes. Paragraphs 7 and 8 of the press release state:
KEVIN SLEVIN FTII, ATT, TEP highlights a grey area in the taper relief provisions which requires urgent attention.
Any reader who has been left no alternative but to advise on the issue of taper relief will know the meaning of the word insecurity so no further comment is called for. However, this article is not another article in the debate about what is and is not to be regarded as a 'security' for the purposes of taper relief.
The Taper Caper
Nothing is ever that simple … especially when it concerns taper relief, warns KEVIN SLEVIN.
One of the biggest problems with the taper relief régime is one of client expectation. Many clients think that they know what taper relief is all about. Hardly a week goes by without someone telling me that he or his client is planning to sell a business shortly after April 2002 when 'there is only ten per cent tax to pay'. Little does he know of the hurdles that he must jump! Many who make disposals long before April 2002 are in for a shock, too.
Salutory tale
