Don’t forget about option holders in private equity deals

The issue Private equity deals often involve the shareholders partially exiting a business by receiving a combination of cash, shares and/or…

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Be careful with discretionary EMI option clauses

The issue Enterprise Management Incentive (‘EMI’) options are a highly tax efficient way for small companies to motivate their employees. They…

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Will we ever know what Zahawi did?

The issue Media has been rife with reports of Nadhim Zahawi’s tax shenanigans. We appear to know the following ‘facts’: 1….

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Paper for paper transactions and ‘lost’ deal costs

The issue It is fairly common for a capital gains tax liability to be deferred under section 135 TCGA 1992 when…

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It pays to return to your rental property

The issue It is fairly common for a property owner to rent out a house that was formerly used as their…

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Ascertainable contingent consideration and foreign currency

The issue When an asset is disposed of, some consideration may be ascertainable but contingent on a future event. If this…

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Grazing agreements are good for SDLT

The issue For higher value property transactions, it is generally preferable to be able to apply non-residential rather than residential stamp…

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Tax advantages of a gift to dying spouse

The issue Although I apologise for the miserable title, deathbed tax planning is never going to be a cheerful activity. It…

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How an inter-spouse transfer can avoid residential capital gains tax rates

The issue Residential property gains effectively have an 8% capital gains tax (‘CGT’) surcharge and so it is preferential for land…

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Can stamp duty share for share relief be claimed for multiple companies?

The issue When a company acquires another company by way of a share for share exchange, the basic rule is that…

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