Exiting Remuneration Trusts can be tricky

Exiting Remuneration Trusts raise a number of issues that need to be addressed.  Finding a tax solution (particularly one that is acceptable!) may have become easier for some with HMRC’s new Settlement Terms recently announced.  Applications to HMRC have to be with HMRC by 31 July 2022, with all computations.  Even then there may stillContinue reading “Exiting Remuneration Trusts can be tricky”

HMRC views some tax avoidance schemes as a “misrepresentation of the true nature of events”

According to HMRC, the fine line between tax avoidance and tax evasion has been crossed and deliberately so.  HMRC’s unit known as Offshore Corporate and Wealthy (OCW) was established in the wake of the ‘Panama Papers’ scandal in 2016 to investigate serious non-compliance by businesses and the wealthiest taxpayers.  Today, the OCW is revisiting aContinue reading “HMRC views some tax avoidance schemes as a “misrepresentation of the true nature of events””

HMRC settlement opportunity for Eclipse Film Partnership members

The Eclipse Film Partners (numbers 1 to 40) Limited Liability Partnerships (Eclipse LLPs) were complex financial arrangements and a form of tax avoidance.  Through their “investment”, taxpayers aimed to generate large interest payments on bank borrowings, presented as contributions to the capital of the Eclipse Film Partnership, so they could buy film rights.  HMRC did notContinue reading “HMRC settlement opportunity for Eclipse Film Partnership members”

Offshore does not mean off HMRC’s radar

The fact a taxpayer has an offshore bank account or an offshore trust or offshore anything can raise or add to the concerns of HMRC.  Not so much as “what is there to hide” but more the fact that its not so transparent compared to being on the mainland UK. So what?

Has a tax scheme promoter left you high and dry? 

Saving tax for clients has always been a major objective for many accountants and other trusted advisors.  And, for many years, accountants and other advisors introduced their clients to a tax scheme promoter who sold various structures both offshore and onshore.

GSOPs and CFDs – HMRC offer an opportunity to reach a Settlement

GSOPs and CFDs were mechanisms designed to reward Directors and key employees in return for achieving specific targets.  The promoters argue that any payments out to an individual under a GSOP or CDF were subject to Capital Gains Tax (CGT).