Ian Zeider

1 month ago | taxjournal.com | Andrew Marr |Sam Epstein |Tom Margesson |Ian Zeider

The impact of the Budget’s proposed reforms to business and agricultural property relief (BPR and APR) has garnered a lot of attention insofar as it will affect farmers – as evidenced by the increasingly popular use of the term ‘family farm tax’. However, it will also have a huge impact on the owners of trading businesses and an even greater impact on trading companies.

1 month ago | taxjournal.com | Andrew Marr |Sam Epstein |Tom Margesson |Ian Zeider

In B Lynch v HMRC [2025] UKFTT 300 (TC) (10 March) the First-tier Tribunal (FTT) upheld discovery assessments of just under £10m on individual steps in a failed avoidance scheme where overall there was no economic advantage. Individual steps could not be ignored where these resulted in tax being chargeable. The taxpayer participated in a marketed tax avoidance scheme for 2010/11 to 2013/14. The scheme was notified under DOTAS.

1 month ago | taxjournal.com | Andrew Marr |Sam Epstein |Tom Margesson |Ian Zeider

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1 month ago | taxjournal.com | Andrew Marr |Sam Epstein |Tom Margesson |Ian Zeider

When we set up discretionary trusts we of course have to bear in mind that these will be subject to the relevant property regime for IHT. This means that the value of the trust is taxed to IHT at up to 6% every 10 years, and to a proportion of 6% on any exit of capital out between 10 year anniversaries. It is possible to set up multiple trusts to help minimise those charges.

1 month ago | taxjournal.com | Andrew Marr |Sam Epstein |Tom Margesson |Ian Zeider

Most of you will know about the tax issues surrounding overdrawn directors’ loan accounts, but it is fairly common for shareholders to have loan accounts that are in credit (where they have lent funds to the company). An acquiror of a company will generally want to remove such a debt as part of a transaction and we have seen ‘heads of terms’ which suggest that such debts should be written off as a preliminary step.