Stephen’s expertise on complex tax

Stephen’s expertise on complex tax matters has proved invaluable on many occasions, he is extremely generous with his time and his assistance is always welcome and gratefully received.

I was impressed by their proactive approach and ability to think outside the box

Having worked with Stephen on a complex management buy-out I was impressed by their proactive approach and ability to think outside the box in providing solutions to tax issues that would otherwise have resulted in significant liabilities crystallising on the individuals concerned.

very impressed with the comprehensive but commercial way in which he provided technical tax structuring advice

I worked with Stephen Burwood on a recent management buy-out and was very impressed with the comprehensive but commercial way in which he provided technical tax structuring advice to the management team. I look forward to working alongside him again.

Categories
Capital Gains Tax

‘Living’ in a property for PRR purposes

Private residence relief provides relief from capital gains tax arising on the disposal of a property which has been the taxpayer’s only or main residence. In the recent tribunal decision of Hezi Yechiel TC06829, consideration was given as to whether, for the purposes of the legislation, Mr Yechiel occupied the property in question, 6 Beaufort Drive, as […]

Categories
Disguised Remuneration Loan Charge Tax Avoidance

Disguised Remuneration – Update

Loan Charge – Government Review Groups who have been campaigning for the 2019 Loan Charge to be scrapped won a small victory last week. They secured an amendment to the Finance Bill which forces the government to review the loan charge legislation by 30 March 2019. This does not remove or alter the loan charge, […]

Categories
Property

Let properties – Interest Relief Restriction

The proportion of finance and interest charges which can be deducted from residential property income is gradually being reduced to nil as follows: Tax Year in which interest is paid Proportion of finance charges deductible 2017/2018 75% 2018/2019 50% 2019/2020 25% 2020/21 and later Nil The landlord will have a tax credit (20% x blocked […]

Categories
SDLT

Reclaim SDLT and LBTT

Since 1 April 2016 a supplement of 3% SDLT has applied to purchases of second and additional homes in England, Wales and Northern Ireland. This supplement was copied in Scotland and became the additional dwelling supplement (ADS) for LBTT, also set at 3% of the entire consideration for properties costing £40,000 or more. A similar […]

Categories
Property

Incorporating a property portfolio business

There is now huge pressure on indebted landlords to incorporate their property businesses, to avoid the restriction on the deduction of interest and other finance charges which has applied since 6 April 2017. Where an actively-managed property portfolio is transferred to a company the gains arising maybe rolled into the value of the shares received, […]

Categories
Share scheme arrangements

EMI Schemes no longer under threat

We have learned today that the EU has now approved a prolongation of the Enterprise Management Scheme (the “EMI scheme”).  The commission decision only applies until the  UK ceases to be a member state. See https://bit.ly/2k3mzo5 which deals with the latest EU decision. HMRC are to issue a bulletin to confirm the position shortly.

Categories
Property

Trading and property allowances

These £1,000 annual allowances were introduced by F(no 2)A 2017, and backdated to apply from 6 April 2017. However, the detailed guidance on exactly how each allowance works has only just been published in HMRC’s Business Income Manual (BIM) and the Property Income Manual (PIM). The trading allowance and miscellaneous income allowance (TMIA), and the […]