Upcoming Tax Surgery with Michael Sherry – 9th July 2018

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


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


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