Corporate Tax Groups – Special rules for Investment Trusts, VCTs and REITs

 CGT, Corporate Groups, Investment Trusts, REITs, Venture Capital Schemes  Comments Off on Corporate Tax Groups – Special rules for Investment Trusts, VCTs and REITs
Feb 262015
 

It has been a while since we last discussed corporate groups, and the notion of intra-group transfers. In this article we shall look at the rules as they apply to investment trusts, VCTs, REITs and other types of company that have a special tax status.

(This article can be downloaded in pdf format at Academia.edu.)

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Rollover Reliefs and the Replacement of Business Assets Part Three – Rolling IP into Shares

 Corporate Groups, Corporate Tax, IP Tax  Comments Off on Rollover Reliefs and the Replacement of Business Assets Part Three – Rolling IP into Shares
Feb 222015
 

This is the last article in our series on asset rollovers. In Part One, we looked at capital assets, in Part Two we saw how IP rollovers work. In this part we shall see how it is possible to sell an IP asset and defer the tax by reinvesting the proceeds in the shares of a company, effectively looking through the corporate vehicle to the underlying IP that it holds.

(This article can be downloaded in pdf format at Academia.edu.)

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Rollover Reliefs and the Replacement of Business Assets Part Two – IP Rollovers

 CGT, Corporate Tax, IP Tax  Comments Off on Rollover Reliefs and the Replacement of Business Assets Part Two – IP Rollovers
Feb 202015
 

This is the second article in our series on asset rollovers. In Part One, we looked at capital assets, in this part, we shall look at IP (we shall use the term IP to cover all intangibles including goodwill).

(This article can be downloaded in pdf format at Academia.edu.)

Recall that a rollover is a means of deferring tax when a business asset is sold and replaced with another. The idea is that since the sale proceeds have been reinvested, the tax doesn’t become due until the second asset is sold and the funds become available.

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Coming Onshore – are Investors better off when Offshore Property Funds Convert to REIT status?

 Investment Tax, Property Tax, REITs  Comments Off on Coming Onshore – are Investors better off when Offshore Property Funds Convert to REIT status?
Feb 162015
 

Shortly before Christmas last year, the financial press reported that the Guernsey investment company F&C UK Real Estate Investments – F&C for short – was planning to “come onshore” and convert to a UK REIT. This is just the latest of a number of closed ended property funds based in the Channel Islands that have taken this step, Standard Life being another well know name to make the change (or to give it its full name, Standard Life Investments Property Income Trust).

What does it mean to “come onshore” and why are these funds doing it now? In the following article, we shall explain the consequences of converting to a REIT, and in particular ask the question “How does it benefit investors?” Continue reading »

Rollover Reliefs and the Replacement of Business Assets – Part One – Capital Assets

 CGT, Corporate Tax  Comments Off on Rollover Reliefs and the Replacement of Business Assets – Part One – Capital Assets
Feb 092015
 

This is the first in a series of articles about asset rollovers, a tax relief available to businesses when one trade asset is exchanged for another. There are two types of rollover, one for capital assets such as land, the other for intangibles such as IP and goodwill (which we shall refer to collectively as IP).

Both types of relief are similar in their operation, but as we shall see, there are important differences. In this article we shall be concentrating on capital assets.

(This article can be downloaded in pdf format from Academia.edu.)
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