In the hot seat

The Excello law summer conference took place on 1 July, the UK’s hottest day for 13 years.  Skimming the conference programme on the way to Stapleford Park, I realised that I was down to give a 20 minute ‘tax insight’ qualifying for CPD points. As I had thought I was going to talk about myself for 20 minutes (an easy task for any lawyer) this meant I had around an hour and a half to get something technical together.

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EBTs: an update after the end of EBTSO – Jo Summers and Jeremy Glover

HMRC withdrew its Employee Benefit Trust (‘EBT) Settlement Opportunity (the ‘EBTSO’) earlier this year.  Until 31 March 2015, HMRC were offering employers of beneficiaries under EBTs a way of settling the uncertainty relating to the taxation of the EBT.

Such uncertainty might relate to HMRC’s stated opinion that the creation of sub-trusts, or the making of loans, to beneficiaries always constituted the making of a taxable distribution to the beneficiary.

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