Pete Miller#11225

Pete Miller, CTA (Fellow)

Head of Corporate Tax, Jerroms Miller Specialist Tax
Pete is Head of Corporate Tax at Jerroms Miller Specialist Tax, a joint venture dedicated to offering expert advice to clients and to other advisers on all business and corporate tax issues. Jerroms Miller specialises in the taxation of corporate reconstructions and reorganisations, HMRC clearances, the transactions in securities rules, distributions, partnerships, Patent Box, disguised remuneration and the taxation of intangible assets.
 
Pete has worked in tax since April 1988, when he joined the Inland Revenue and trained as an Inspector of Taxes. He worked in Birmingham and London with roles in both Policy and Technical Divisions, where he was the Inland Revenue’s expert on all matters relating to the distributions legislation. He then worked for 11 years in ‘Big 4’ firms and, from 2011 to 2022, Pete ran his own business, The Miller Partnership, , specialising in the taxation of corporate transactions.
 
Pete is lead author of Taxation of Company Reorganisations (6th edition, Bloomsbury Professional, October 2020), co-author of CCH’s book on Taxation of Partnerships and author of Tax Digests on Corporate Reconstructions, Transactions in Securities, Partnership Taxation, Disguised Remuneration, the Substantial Shareholding Exemption and the Patent Box and of the ICAEW Tax Faculty’s TAXGuide on the 2017 regime for carried forward corporate losses.
 
He also speaks and writes regularly on tax issues and is General Editor of Whiteman and Sherry on Capital Gains Tax and on Income Tax and a member of the Editorial Boards of Taxation, The Tax Journal and Simon’s Taxes.
Contributed to

1

Sale of a company out of an employee ownership trust
Sale of a company out of an employee ownership trust
Practice Notes

This Practice Note examines some of the key tax and practical considerations that arise when a company owned by an employee ownership trust (EOT) is sold out of the EOT. These issues include the need for the trustees to consider whether the sale is in the best interests of beneficiaries, taking account of any capital gains tax (CGT) for which the trustees may be liable and any debts owed to the parties from whom the EOT originally acquired the company, potential difficulties in identifying and tracing all of the EOT beneficiaries who may be entitled to the surplus sale proceeds, and the operation of PAYE and NICs in respect of distributions to those beneficiaries.

Practice Area

Panel

  • Contributing Author

Experience

  • Jerroms Miller Specialist Tax (2022 - Present)
  • The Miller Partnership (2011 - 2022)
  • Powrie Appleby (2009 - 2011)
  • Tenon (2008 - 2009)
  • Ernst & Young (2001 - 2008)
  • KPMG (1997 - 2001)
  • Inland Revenue (1988 - 1997)

Membership

  • Chartered Institute of Taxation
  • Worshipful Company of Tax Advisors

Qualification

  • BSc (hons) (Biochemistry) (1984)

Education

  • Queen Elizabeth College, London University (1984)
  • Richard Hale School, Hertford (1977)

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