DAVID BYWATER and GAVIN ORDE summarise the important aspects of the loan relationship rules for family companies.
THE TOPIC OF loan relationships is a hazy area to many people; the purpose of this...
The remittance regime can produce some very odd results, says ROBERT MAAS as he tunnels down into an Alice in Wonderland world of shrinking tax liabilities.
Our client property development company has been trading successfully for ten years. There are two shareholders; A holds 500 A ordinary shares and B holds 500 B ordinary shares.Throughout the...
Correspondence from readers on topical subjects.
Crossroads?
I have read the latest article by Richard Curtis ('Crossroads?', Taxation, 27 July 2006, page 451) with great interest, as I have previous...
I am sure that there is an easy answer to this question, but I would be most grateful if Taxation readers could put my mind to rest on it.My client started trading last year and has just registered...
We have recently taken a new case comprising a self settled trust and the settlor's personal tax. The trust holds an investment in an offshore unit trust from which it receives untaxed dividends in...
A client owned shares in a trading company which, some ten years ago, were sold for cash and non-qualifying corporate bonds. The loan note agreement says that 'the company hereby covenants that unless...