HMRC have given a clearance for the reconstruction of a holding company and its two subsidiaries into two separate companies. The clearance states that it does not extend to a sale or liquidation of the new companies. What are the implications?
An individual who is resident and domiciled in the UK owns all of the share capital in a Delaware company. If this company is wound up by a liquidator in the UK, and the company’s retained profits are distributed, would the payment be treated as an income or capital distribution?