October Tax Surgeries for Liverpool and Manchester

Manchester

Tuesday 2nd October 2018 4:00pm – 5:00pm
Centurion House, Room 1, 129 Deansgate, Manchester, M3 3WR
Followed by drinks and a chance to discuss the issues. No charge for attendance.

Liverpool

Wednesday 3rd October 2018 4:30pm – 5:30pm
Red Room 3 The Plaza Old Hall Street, Liverpool
Followed by drinks and a chance to discuss the issues. No charge for attendance.

Trusts and Tax When is trust not a trust?

(with/without the use of an LLP as an intermediate stage)

Your Speaker in October 2018 is Michael Sherry

Covering:

Recent trust busting cases in England & Jersey

– substance over form
– implications for tax practitioners
– how do they fit with Ramsay/UBS etc

MezProm v Pogadev (and time permitting Crociani v Crociani)

What happened?
Were the trust valid?
The protector’s powers and their effect in the circumstances Sham?
The court’s decision
The points to take away – trusts/tax

September Tax Surgeries for Liverpool and Manchester

Liverpool

Tuesday 11th September 2018 4:30pm – 5:30pm
Red Room 3 The Plaza Old Hall Street, Liverpool
Followed by drinks and a chance to discuss the issues. No charge for attendance.

Manchester

Wednesday 12th September 2018 4:00pm – 5:00pm
Red Room – Calyco, St James’ Building 61 – 95 Oxford Street, Manchester, M1 6EJ
Followed by drinks and a chance to discuss the issues. No charge for attendance.

The pros and cons of incorporating a buy to let business from a CGT perspective

(with/without the use of an LLP as an intermediate stage)

Your Speaker in September 2018 is Michael Sherry

Covering:

  • Meaning of business different for individual/company – American Leaf
  • Section 162 transfer of business
  • LLPs as an intermediate stage?
  • Incorporation of LLP’s business with/without liquidation
  • DOTAS

As with previous sessions Michael will be working through some examples. However if participants would like to raise their real life problems that would be welcomed. Any specific examples you would like to raise should be sent to us a week before the session Numbers for these sessions are strictly limited. Early booking is essential – please email claire.labio@completecounsel.co.uk

Charles Feeny to speak at two major events this summer

Charles Feeny will be speaking at two major events in London in the coming weeks.

Charles Feeny

On 26 June, Charles has been invited to speak at a seminar organised by leading insurance firm BLM at their London office. The seminar will focus on industrial disease and Charles has been asked to address the issue of date of knowledge in mesothelioma claims.

Charles has appeared in a number of the leading cases in this area of law, most recently Bussey v Anglia Heating. The implications of the Court of Appeal Judgment in Bussey are still being assessed and further litigation in this difficult and emotive area can be anticipated.

On 5 July, Charles will speak at and moderate a session on lesson-learning in self-harm and suicide claims in the context of mental illness. This follows his instruction in a number of cases against NHS Trusts in this area.

The event is a national conference at the Institute of Child Health in London organised by NHS Resolution under the title of “Mental Health Matters – Leaning from the Frontline”. The conference represents part of NHSR’s ongoing commitment to improve standards of patient safety, including by reference to lessons learnt from litigation.

Speaking at these events is consistent with Charles’ commitment to education, training and debate in relation to legal issues. He focuses his activities in this area on the website Pro‑VIDE-Law.

>>> Download flyer for ‘Mental health matters – Learning from the frontline

>>> View information for the Occupational Disease Seminar

Upcoming Tax Surgery with Michael Sherry – 9th July 2018

Disguised remuneration: A Case Study
Your Speaker on 9th July 2018 is Michael Sherry

Covering:

the 2019 charge – repayment of loans;
– Sale of assets to trustees?
– Tax avoidance? Purpose/motive;

Employer insolvent – PAYE/NIC recovery from e’ee?
– Reg 72, 81 and applicable PAYE code?
– Possible changes to directors liabilities?

IHT – EBT and EFRBS. Does s.86 apply?
– Rangers in the context of IHT?
– BPR on ‘contributions’
– Relevant property charges – exit, 10 yr an, etc.

Future distributions – Linked persons and future generations
– Pt7A charge franked from insolvency settlement?
– Contributions from EBT/EFRBS to insolvency for beneficiary?

Insolvency – Malfeasance
– Unlawful dividends
– Scheme contributions as voluntary dispositions which can be set aside?

Residual risks – GAAR
– Future law changes
– Inherent legal uncertainty

 

Upcoming Tax Surgery – Family investment companies, 13th June 2018

Where are we now – risks and advantages plus family constitutions.

Your Speaker on 23rd May 2018 is Michael Sherry

Family investment companies:

• Entrepreneurs relief vs Substantial shareholding exemption
• Possibilities for BPR
• Modifying shareholdings to give gradual shift of value
• Freezer shares
• Voting only shares
• Capital reduction shares
• (Accidental) Destruction of value and immediately chargeable transfers
• Share valuation – from Jamieson through Crossman and Buccleuch to Gray’s Timber
• Gearing?
• Family constitution purpose form and functions

Wednesday 13th June 2018, 4:00pm – 5:00pm

Red Room – Calyco, St James’ Building 61 – 95 Oxford Street, Manchester, M1 6EJ

Followed by drinks and a chance to discuss the issues. No charge for attendance.

To register, email claire.labio@completecounsel.co.uk

Tax Surgery with Michael Sherry – 16th May 2018, Manchester

Your Speaker on 16th May 2018 is Michael Sherry.

Wednesday 16th May 2018
4.30pm-5.30pm
Calyco Room, St James’ Buildings,
Oxford Street, Manchester

Followed by drinks and a chance to discuss the issues.

Topics covered

A general update and specific issues including:

• Part 7 Ch1 to 4 overview
Case law
• the general background;
• Grays Timber, Tower Radio, UBS, Cyclops etc.
Specific issues
• offshore
• salary reduced and dividends on new acquired shares
• voting/not voting for dividends shortly after acquisition –
effect on value?
• ERS return where shares are SEIS/EIS?
• gifts between shareholder “partners” to reflect changing
contribution to business
• demergers share exchanges etc and s.431?
• employee control defence when s 431 absent?
• effect of purchase of own shares on value

Tax Surgery: Family investment companies – 23rd May 2018

Where are we now – risks and advantages plus family constitutions.

Your Speaker on 23rd May 2018 is Michael Sherry

Family investment companies:

• Entrepreneurs relief vs Substantial shareholding exemption
• Possibilities for BPR
• Modifying shareholdings to give gradual shift of value
• Freezer shares
• Voting only shares
• Capital reduction shares
• (Accidental) Destruction of value and immediately chargeable transfers
• Share valuation – from Jamieson through Crossman and Buccleuch to Gray’s Timber
• Gearing?
• Family constitution purpose form and functions

Private Client Tax Surgery with Michael Sherry

Monday 23rd April
4.30pm – 5.30pm

Red Room – Calyco, St James’ Building
61 – 95 Oxford Street, Manchester, M1 6EJ
Followed by drinks and a chance to discuss the issues.

No charge for attendance.

The seminar will concentrate on business property relief:

  • review of cases (including recent decision in Ross)
  • the 2 year rule and replacements
  • why every client should have a company
  • flexible will trusts

Attendees are encouraged to raise problems experienced in practice. Any summary of a practice problem submitted at least 24 hours before the seminar will be considered during the session.

Questions and discussion are welcomed.

As with previous sessions Michael will be working through some examples. However if participants would like to raise their real life problems that would be welcomed. Any specific examples you would like to raise should be sent to us a week before the session.

Numbers for these sessions are strictly limited. Early booking is essential – please email claire.labio@completecounsel.co.uk

Deportation and Withdrawal of British Citizens

Join Lorraine Mensah for a short session on this hot topic.

Lorraine Mensah

Lorraine was appointed Immigration Judge in 2007.

She provides specialist advice in the areas of European law and specifically rights for workers, Nationality issues, Immigration applications both under Appendix FM and the Points based system, deportation and Human Rights and has acquired significant experience in this field.

Lorraine has also been instructed in multiple high profile serious foreign criminal cases.

Tuesday 1st May 2018
Ground Floor, The Plaza
4.30 – 5.30 pm

Followed by drinks and a chance to discuss the issues.

Upcoming Tax Surgery with Michael Sherry – Wednesday 21st March

Topics covered

A general update and specific issues including:

• Part 7 Ch1 to 4 overview

Case law

• the general background;
• Grays Timber, Tower Radio, UBS, Cyclops etc.

Specific issues

• offshore
• salary reduced and dividends on new acquired shares
• voting/not voting for dividends shortly after acquisition – effect on value?
• ERS return where shares are SEIS/EIS?
• gifts between shareholder “partners” to reflect changing contribution to business
• demergers share exchanges etc and s.431?
• employee control defence when s 431 absent?
• effect of purchase of own shares on value

Wednesday 21st March 2018
Ground Floor, The Plaza
4.30pm-5.30pm

Followed by drinks and a chance to discuss the issues.

Contact us to book your place.