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Dec 19, 2024 | 
investment-international.com | Chris Etherington
Following the UK government's Autumn Budget, more families are likely to be worried about exposure to inheritance tax and with it being the season of goodwill, some may be considering larger gifts than usual to family members, says RSM's Chris Etherington. Many will be aware of the general rule that someone’s exposure to inheritance tax (IHT) can be reduced if gifts are made during their lifetime.
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Nov 5, 2024 | 
investment-international.com | Chris Etherington |Mark Battersby
One of the biggest shockwaves from Rachel Reeves’ first Budget was felt by those with large pension pots, with many to be brought within the inheritance tax (IHT) net from 6 April 2027. As a result, some taxpayers may find the foundations of their IHT planning is now on shaky ground, according to RSM's Chris Etherington. At the moment, the majority of unused pension funds do not form part of an individual’s estate for IHT purposes.
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
The GAAR Advisory Panel has issued an opinion on arrangements which sought to reward a company’s director in a way ‘that would not be any form of remuneration’. This involved creating an obligation to make pension payments to the individual transferring that obligation to a third party and paying the third party for accepting that obligation. In essence the full amount that otherwise would have been paid to the individual was instead routed via the third party.
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
Chancellor Rachel Reeves delivered her first Budget on 30 October 2024. Together with the headline increase in employer NICs the Chancellor’s changes to CGT rates and reform of IHT reliefs are expected to impact on businesses with carried interest also brought into focus.
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
In GCH Corporation Ltd and others v HMRC [2024] UKFTT 922 (TC) (17 October), the FTT allowed the taxpayers’ appeals against capital taxes assessments relating to a transfer of loan notes to a limited liability partnership by its members. Gregory Hutchings (GH), who worked in senior positions at Tomkins PLC (Tomkins) until 2000, was the trustee of three family trusts (‘the trusts’).
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
In S Lefort v HMRC [2024] UKFTT 926 (TC) (17 October) the FTT upheld HMRC’s decision to revoke the taxpayer’s certificate of fixed protection under the legislation reducing the pension schemes lifetime allowance in 2014. The taxpayer was an airline pilot employed by Virgin Airlines. He had a self-invested pension plan (SIPP) into which he and Virgin made contributions. He left the company in February 2014 making a final contribution to the plan and obtained a Fixed Protection 2014 certificate.
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
HMRC have decided to disband the Joint Forum on Expatriate Tax and NICs (the Expat Forum) informing members that the ‘group’s effectiveness has reduced with an increasingly long list of unresolved issues’ and suggesting that many of the live issues would be more suitably dealt with via other channels.
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
In Abbeyford Caravan Company (Scotland) Ltd v HMRC [2024] UKFTT 928 (TC) (17 October), the FTT allowed the taxpayer’s appeal against a decision by HMRC that it could not apply a more favourable method of output tax apportionment retrospectively. It reached that decision after finding that the difference between the old method and the new method was substantial. The taxpayer bought and sold caravans with removable contents, charging a single price for each caravan and its contents.
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
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