Sam Epstein

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

The ‘no disqualifying arrangements requirement’ (ITA 2007 s 178A) was introduced into the Enterprise Investment Scheme (EIS) legislation by FA 2012 and applies to all EIS shares that have been issued since 6 April 2012. It was introduced as anti-avoidance legislation to target arrangements which the Government saw arguably rightly as outside the spirit of the legislation.

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.