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Rayney’s Tax Planning for Family and Owner-Managed Companies: 2023/24

Peter Rayney FCA, CTA (Fellow), TEP
Bloomsbury Professional
Publication Date:
Law Stated At:
6 April 2024
D Damages breach of warranty, 12.75 Data rooms business acquisitions, and, 12.4A Date of disposal sale of business, and, 15.3 Death benefits vesting of funds, and generally, 10.42 member dies aged 75 or over, 10.43A member dies before 75th birthday, 10.43 Death-in-service pensions inheritance tax, and, 17.52 Death, transfers on (IHT) business property relief, 17.16 calculation of chargeable estate, 17.14 deeds of variation, 17.18 liabilities, and, 17.14A nil rate band transfer chargeable estate, 17.14 liabilities, 17.14A pre-deceased spouses, 17.15 reduced death rate, 17.14B planning, 17.50 – 17.51 pre-deceased spouses, 17.15 reduced death rate to 36% for charitable bequests, 17.14B return by PRs, 17.14 shares planning, 17.48 – 17.49 valuation, 17.17 will drafting, 17.50 Debt-for-equity swap accounting issues, 11.24A borrower’s tax treatment, 11.24 commercial rationale, 11.23 conditions for relief, 11.24B legal issues, 11.24A lender’s tax position, 11.26 tax group reliefs, 11.25 unused trading losses, 11.25 Debt security See Loan notes See ...

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