A convertible security is a share or bond which may be converted into another type of share or bond. The right to convert may be unconditional, or may depend on a stated set of future circumstances. Sometimes the right to convert may be acquired later. The significance in terms of tax is chiefly to do with securities acquired through employment (employment-related securities). Without specific legislation it would be possible to reward an employee with shares of a certain value (and subject to tax on that value) which could later be converted to securities of a higher value. Not surprisingly, there are detailed rules designed to bring into the tax net any such subsequent increase in value. There is a specific tax definition of the term "convertible securities" which may be considered to be wider in scope than a straightforward commercial definition, and as such needs to be considered very carefully by employers wishing to reward employees in this way.
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IntroductionConsortium relief enables losses of a consortium company to be transferred to consortium members in proportion to the consortium member’s interest in the consortium company, and vice versa. Consortium relief is a flexible relief which is available in several different scenarios which are
Arguably, the most important exemption from IHT is the married couple / civil partner exemption.There is no IHT to pay on gifts from husband to wife and vice versa, or from one civil partner to the other (referred to collectively in this note as ‘spouses’). The exemption applies to inter-spouse
Statutory references to ITTOIA 2005 relate to unincorporated businesses and CTA 2009 relate to companies unless otherwise stated.Legal and other professional fees can represent substantial costs to a business. A detailed analysis is often required for the purpose of preparing tax computations as
This guidance note explains how to calculate the amount of tax that arises under the lifetime charge. In general terms the lifetime charge will apply to individuals who transfer property into a trust that is subject to the relevant property regime. See the Chargeable transfers and Occasions of