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Informa
Jul 03
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08:30 - 09:00 30 mins
Registration
09:00 - 09:10 10 mins
Chairman’s Opening Remarks
  • Patrick Cannon - Barrister, 15 Old Square Tax Chambers
09:10 - 09:50 40 mins
The 4 Different SDLT Rate Structures and Mixed-use Property
  • Gordon Keenay - Head of Stamp Taxes, FTI Consulting
09:50 - 10:30 40 mins
Problems and Issues with the 3% Additional Rate
  • The changes made by the Autumn Budget 2017 to the higher rates
  • The revised Guidance in the Manual of April 2018
  • The replacement exception
  • The interaction between the higher rates and multiple dwellings relief
  • John Shallcross - Associate, Blake Morgan
10:30 - 11:10 40 mins
Developments with Follower Notices and APNs in SDLT and Other Taxes
  • David Southern QC - Barrister, Temple Tax Chambers
11:10 - 11:30 20 mins
Morning Refreshment Break
11:30 - 12:10 40 mins
Recent SDLT Cases: Project Blue, Geering etc
  • Alternative finance, sub-sales and section 75A: Project Blue 
  • Unlimited company sub-sales, sections 45 and 75A: Geering v HMRC
  • Closure notices and sub-sales: Crest Nicholson
  • Reasonable excuse: Latimer Hill 
  • Proving a disclosure letter was sent: Alison Lloyd 
  • Patrick Cannon - Barrister, 15 Old Square Tax Chambers
12:10 - 12:30 20 mins
First-time Buyers Relief: Do I Know It All?
  • Toby Price - Head of Stamp Taxes, Deloitte
12:30 - 12:50 20 mins
Overview: SDLT Issues Around Collapsing Unit Trust Schemes
  • Basic analysis for distribution from unit trust scheme, including consideration of whether group relief and/or distribution relief in s54(4) FA 03 can apply.
  • The (severe) challenges to that basic analysis where (i) the trustees have taken direct bank borrowing and/or given security for such borrowing (ii) the trust owes money to the unit holders and (iii) the property is held through a partnership rather than directly by the trust.
  • Toby Price - Head of Stamp Taxes, Deloitte
12:50 - 13:00 10 mins
Questions to Speakers on Morning Sessions
13:00 - 14:00 60 mins
Lunch
14:00 - 14:30 30 mins
Scottish LBTT and Welsh LTT
14:30 - 15:10 40 mins
Demystifying SDLT and Trusts
  • What is a settlement for SDLT
  • Acquisitions and disposals
  • Bare Trustees – difficulties arising
  • Transferring assets within the Trust
  • Additional 3% rate
  • Trustee partners
  • Sara Maccallum - Senior Partner, Boodle Hatfield
15:10 - 15:30 20 mins
Afternoon Refreshment Break
15:30 - 16:00 30 mins
Professional Negligence and Miss-sold Avoidance Schemes
16:00 - 16:40 40 mins
SDLT and Property Developers: Sub-sales, Land Pooling and Partitions etc

SDLT issues for Property Developers including:

  • Land Pooling and Partitioning
  • Joint ventures
  • Slice of the action schemes
  • Sub-sales
  • Treatment of the value of works
  • Leigh Sayliss - Head of Business and Property Taxes, Howard Kennedy
16:40 - 17:00 20 mins
Questions to Speakers
17:00 - 17:10 10 mins
Chairman’s Summation
  • Patrick Cannon - Barrister, 15 Old Square Tax Chambers