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19 January 2017

Tax Treatment of Employment Related Securities

Gain a comprehensive coverage into the latest updates and implications of Part 7 of ITEPA for Companies & Private Equity Firms

Chaired by Mahesh Varia, Partner, Travers Smith

Key Highlights Include:

Management Tax on MBO’s
  • Structuring the best deal for management teams
  • Recent trends in management incentives
  • Capital gains tax reliefs
  • Is the HMRC/BVCA MoU on valuation still relevant?
  • Tax clearances following the amended transaction in securities rules
  • How to structure a second tier incentive
  • The international aspect
ERS and Internationally Mobile Employees
  • The Rules on taxation – the need to know
  • Interaction and the Application: New rules vs Old Rules
  • The impact on universal application for employees who move jurisdiction
  • HMRC what’s on their radar – The Revenue’s objectives discussed
  • Potential impact on changes to Non-Dom tax status (in particular those domiciled post 6th April 2017)
  • Expected Share Plan and Accounting Changes
  • Summary of recent changes
P House Aspects of Corporate Structures. Fund Issues and Carried Interest
  • Key elements of fund structures
  • 2003 BVCA/HMRC memorandum of understanding
  • Issues for remittance basis users and US citizens
  • What does the future hold? HMRC Consultation on Fund Managers’ Performance Interests

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