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Edge EBT thread

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    PM Access

    Originally posted by GoneSouth View Post
    If you have any desire to pursue group representation please see Norla/Edge Former Employee EBT Self Help Group

    Request PM (private message) access if you don't already have it. You can post a request or contact the admins via this page: http://forums.contractoruk.com/sendmessage.php

    PM TheDandy here: http://forums.contractoruk.com/priva...=newpm&u=39502
    PM Saleos here: http://forums.contractoruk.com/priva...=newpm&u=41765

    then make a decision if you have interest in one or both of the groups and if you are willing to foot the likely costs and advise the organiser(s) accordingly

    Simply posting a desire to join a group will not achieve anything.


    Sorry for the repetition but I want to ensure latecomers are informed

    GS
    Hi,

    Could I get PM rights please ?

    Comment


      Voluntary settlement

      I can provide a free assessment of a potential voluntary settlement with HMRC and will need some information to do that.

      I am not advocating such a settlement but it needs to be considered if you have a dispute with HMRC.

      I reserve the right to provide you with my credentials and fee structure with no obligation whatsoever.

      You can send me a private message (subject to admin approval).

      Comment


        So what happened to the Ranger FC vs HMRC Case?

        Apologies in advance, but I seemed to have missed the news on

        " what happened to the Ranger FC vs HMRC Case? "

        cheers

        Comment


          Originally posted by IPMAN View Post
          Apologies in advance, but I seemed to have missed the news on

          " what happened to the Ranger FC vs HMRC Case? "

          cheers
          The verdict has not been announced yet...
          merely at clientco for the entertainment

          Comment


            Originally posted by eek View Post
            The verdict has not been announced yet...
            ah so a verdict has been reached?, and if so I wonder why the gagging order?

            the 'join group' activity seems to be have momentum and to a large degree I support that, but if we review Michelle's appeal letter and specifically the reference to Rangers FC case, should we really be mega concerned at this stage?.

            Comment


              I'll correct my previous statement as the case is due to be held in public between Jan and March Rangers EBT tax case HMRC appeal to be heard in public, judge rules | Glasgow & West | News | STV (I truely thought it had been held and we were just waiting for the verdict).

              I'm not involved in any of these claims (I keep my accounts simple as I like to sleep at night) and others would say that I'm biased but you may want to read http://forums.contractoruk.com/hmrc-...ings-news.html. The bit were insiders feel that HMRC will win is based on ABERDEEN ASSET MANAGEMENT PLC v. THE COMMISSIONERS FOR HER MAJESTY'S REVENUE AND CUSTOMS IN RESPECT OF A DECISION OF THE UPPER TRIBUNAL (TAX AND CHANCERY CHAMBER), 23 October 2013, Lord Drummond Young+Lord Glennie+Lord President which is a binding result that impacts other cases.
              merely at clientco for the entertainment

              Comment


                Zarkana's post moved to: http://forums.contractoruk.com/accou...ml#post1890767
                "I can put any old tat in my sig, put quotes around it and attribute to someone of whom I've heard, to make it sound true."
                - Voltaire/Benjamin Franklin/Anne Frank...

                Comment


                  Originally posted by eek View Post
                  I'll correct my previous statement as the case is due to be held in public between Jan and March Rangers EBT tax case HMRC appeal to be heard in public, judge rules | Glasgow & West | News | STV (I truely thought it had been held and we were just waiting for the verdict).

                  I'm not involved in any of these claims (I keep my accounts simple as I like to sleep at night) and others would say that I'm biased but you may want to read http://forums.contractoruk.com/hmrc-...ings-news.html. The bit were insiders feel that HMRC will win is based on ABERDEEN ASSET MANAGEMENT PLC v. THE COMMISSIONERS FOR HER MAJESTY'S REVENUE AND CUSTOMS IN RESPECT OF A DECISION OF THE UPPER TRIBUNAL (TAX AND CHANCERY CHAMBER), 23 October 2013, Lord Drummond Young+Lord Glennie+Lord President which is a binding result that impacts other cases.

                  Don't agree at all. AAM decision came before FTT gave its decision on Rangers case. After AAM ruling, both sides did another submission. AAM was clearly bonus money in complete control of employees. Rangers was Loans with valid legal repercussions and employees did not had full control. Jury in Rangers considered the AAM ruling before giving the decision. For those who are interested both and some other decisions available in links below. Best is read yourself instead of relying on articles on Internet.

                  https://dl.dropboxusercontent.com/u/...%20PLC%20v.pdf
                  https://dl.dropboxusercontent.com/u/...20decision.pdf
                  https://dl.dropboxusercontent.com/u/.../dextra_sp.pdf
                  https://dl.dropboxusercontent.com/u/...0Decision.docx

                  Rangers UTT hearing is starting from 24th Feb to until 21st Mar: http://www.justice.gov.uk/downloads/...s-register.pdf

                  Remember Ranger was an EBT which was not that strongly implemented for example side letters. In many other case, nothing even remotely like side letters exists. HMRC did not appealed Dextra in 2008 and is now is saying in Ranger's case that ruling was wrong, which FTT decisions makes a strong note of.

                  Also in many case with full disclosure on Self assessment, HMRC is out of time as proved in http://www.tribunals.gov.uk/financea...d-corfield.pdf
                  Last edited by varunksingh; 16 February 2014, 20:25.

                  Comment


                    Originally posted by varunksingh View Post
                    Don't agree at all. AAM decision came before FTT gave its decision on Rangers case. After AAM ruling, both sides did another submission. AAM was clearly bonus money in complete control of employees. Rangers was Loans with valid legal repercussions and employees did not had full control. Jury in Rangers considered the AAM ruling before giving the decision. For those who are interested both and some other decisions available in links below. Best is read yourself instead of relying on articles on Internet.

                    https://dl.dropboxusercontent.com/u/...%20PLC%20v.pdf
                    https://dl.dropboxusercontent.com/u/...20decision.pdf
                    https://dl.dropboxusercontent.com/u/.../dextra_sp.pdf
                    https://dl.dropboxusercontent.com/u/...0Decision.docx

                    Rangers UTT hearing is starting from 24th Feb to until 21st Mar: http://www.justice.gov.uk/downloads/...s-register.pdf

                    Remember Ranger was an EBT which was not that strongly implemented for example side letters. In many other case, nothing even remotely like side letters exists. HMRC did not appealed Dextra in 2008 and is now is saying in Ranger's case that ruling was wrong, which FTT decisions makes a strong note of.

                    Also in many case with full disclosure on Self assessment, HMRC is out of time as proved in http://www.tribunals.gov.uk/financea...d-corfield.pdf
                    So the binding upper tribunal decisions published in October 2013 predate the Rangers FTT case 25 October – 5 November 2010 until 16-18 January 2012? Remember its only upper tribunal and supreme court decisions that are binding and thats only after the verdict is given.

                    Look I really don't want to enter into arguments with you but I'm getting more than a slightly annoyed with the falsehoods you state as fact...
                    merely at clientco for the entertainment

                    Comment


                      Originally posted by eek View Post
                      So the binding upper tribunal decisions published in October 2013 predate the Rangers FTT case 25 October – 5 November 2010 until 16-18 January 2012? Remember its only upper tribunal and supreme court decisions that are binding and thats only after the verdict is given.

                      Look I really don't want to enter into arguments with you but I'm getting more than a slightly annoyed with the falsehoods you state as fact...
                      I am also not interested in any useless arguments. So last post from my side on this matter and all can see for them selves. Directly COPIED and PASTED below from Rangers decisions

                      ====
                      197. That view, however, falls to be clarified by the recent opinion of Warren J in Aberdeen Asset Management plc v HMRC in the Upper Tribunal (“AAM”). While that decision post-dates by a few days counsels’ closing submissions in this Appeal, both sent subsequently written submissions on the decision. That case involved benefits to employees by way of share transfers. In para 40 of his decision Warren J interprets Walton J as indicating that payment would result from funds being placed unreservedly at the employee’s disposal, but (perhaps) it was not a necessary condition for payment. However, later in his decision [para 83] Warren J considered that for the purposes of Section 203 ICTA 1988 it was a “… necessary even if not sufficient condition for there to be a payment …” that monies should be unreservedly at the employee’s disposal.
                      ====

                      Agree 100% with "Remember its only upper tribunal and supreme court decisions that are binding and thats only after the verdict is given". HMRC should also agree with this. AAM was considered and does not apply to Ranger's EBT DIRECTLY ONE FOR ONE. Some parts will always overlap. Similarly AAM decision does not apply to all EBT's ONE FOR ONE.

                      Comment

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