After over 30 years in tax, initially with a corporate tax bias but gravitating towards OMB tax matters, over the last decade it is only possible to highlight a short(ish) list of specialisms. One of the skills of a tax author is being able to analyse sometimes highly complex tax law and advise with confidence on a broad range of direct tax issues. That said the days when it was possible to be an all-round tax expert are long gone and some things are best left to the experts in their various fields. I don’t for example give advice on VAT and am generally not set up to take on tax return preparation and other tax compliance work.
Below is a selection of my specialisms.
- Capital gains tax (CGT) Entrepreneurs’ Relief (ER)
- Incorporation of businesses and company disincorporation
- Tax residence including the Statutory Residence Test (SRT), the effect of Double Taxation Agreements (DTAs) and remittance basis.
- Company reconstructions, including Management Buy-Outs (MBOs).
- Demergers – statutory demergers, liquidation demergers and demergers by capital reduction
- CGT private residence exemption
- Company purchase of own shares (and alternative structures)
- Enterprise Investment Scheme (EIS) and Seed Enterprise Investment Scheme (SEIS)
- CGT Substantial Shareholdings Exemption
- Non-residents’ UK property and other interests
- Stamp Duty Land Tax (SDLT)
- Inheritance Tax (IHT)
- Employee share awards and share options – generally and via the Enterprise Investment Scheme (EMI)
- Benefits in kind and PAYE issues
- HMRC enquiries and arguments with HMRC over technical issues – usually successful!
- Stamp Duty relief for company reconstructions
- Applications to HMRC for informal clearance e.g. re company trading status for ER purposes
- Statutory clearance applications for various corporate transactions (including s.138 TCGA 1992 and s.701 ITA 2007)
- Company sales and acquisitions including structuring earn-out structures, loan notes etc.
- Property letting and other property tax issues
- Non-residents CGT and other issues
- CGT gift relief and other CGT reliefs
- Trusts and settlements
