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Edge EBT thread

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  • jbeer
    replied
    Originally posted by csharper View Post
    Do you want to contact the trust to get it written off and pay IHT now?
    I guess not.
    Probably not but think it would be prudent to find out if it could be written off

    Leave a comment:


  • KRAMB
    replied
    Originally posted by csharper View Post
    Do you want to contact the trust to get it written off and pay IHT now?
    I guess not.
    If IHT is a valid concern then it could become more of a problem than the Income Tax HMRC state is owed.
    If it would be possible to defer the IHT payment until Death then this would probably have the effect of reducing any estate remaining - solution for some ?
    That's a lot of tax accruing at 1% tax per Year until write-off including Interest if payment due dates are applicable and not met. So, it would be best trying to wrestle this issue now before amounts become astronomical

    I am uncertain on the subject - if HMRC lost / dropped their case against the Edge arrangement then would each Member still be liable for IHT as the scheme used a Trust. - the longer it takes for HMRC to challenge the Edge scheme the more IHT that becomes due

    Leave a comment:


  • csharper
    replied
    Originally posted by jbeer View Post
    Hi, just wondering if you managed to confirm these were the trustees for the edge scheme ?

    Also was wodering if anyone knew of edge users having their loans written off ?
    Do you want to contact the trust to get it written off and pay IHT now?
    I guess not.

    Leave a comment:


  • csharper
    replied
    Originally posted by Saleos View Post
    Under the CLSO HMRC accept that if you were non-UK domiciled when the loans were made to you and they are written of when you are non-UK resident then no IHT will be due.

    I have agreed the wording of a formal settlement agreement with HMRC on that basis. Contact me if you wish to benefit from my assistance to secure that.

    Regards
    Thanks. I was domiciled and resident when I received the loans. Haven't heard if they are written off?
    I have not been contacted by Edge or Trust telling me that they are written off.

    Leave a comment:


  • jbeer
    replied
    Thanks!

    Leave a comment:


  • Saleos
    replied
    The current trustees of the Edge EBT are:


    Winnell T P & Co
    7, Hill St, Douglas,
    IM1 1EF

    01624 670022

    Good luck!


    Originally posted by jbeer View Post
    Hi, just wondering if you managed to confirm these were the trustees for the edge scheme ?

    Also was wodering if anyone knew of edge users having their loans written off ?

    Leave a comment:


  • Saleos
    replied
    Under the CLSO HMRC accept that if you were non-UK domiciled when the loans were made to you and they are written of when you are non-UK resident then no IHT will be due.

    I have agreed the wording of a formal settlement agreement with HMRC on that basis. Contact me if you wish to benefit from my assistance to secure that.

    Regards

    Originally posted by csharper View Post
    It will apply to you even if you don't agree a settlement and then lose the case in tribunal.

    And I am a non-resident non-domicile.

    Leave a comment:


  • webberg
    replied
    Originally posted by jbeer View Post
    Just thinking this through. Edge loans were interest free so is it not just a case of factoring in inflation, £1 10 years ago is worth less today ?
    No. They have always been interest free and as such that part of the valuation equation has always been zero.

    The lender (a trustee who has an obligation to protect his beneficiary) must have consider upon making the loan the the borrower would repay the whole amount and as the trustee had no interest to service, was no bothered with interest received. What has changed is that the ability/intention of the borrower to repay has been compromised and/or the trustee has made a unilateral decision on this and has failed to inform the borrower.

    Either way a breach of the trustees obligations perhaps?

    Leave a comment:


  • jbeer
    replied
    Just thinking this through. Edge loans were interest free so is it not just a case of factoring in inflation, £1 10 years ago is worth less today ?

    Leave a comment:


  • jbeer
    replied
    Thanks.

    That does seem strange. I spoke with IHT department and they said the iht liability could only be settled when trustees confirm loan write off. Unless people have asked for a caclulation for iht if it was written off and the clso team have misinterpreted this ? But sounds unlikely from what you say.

    Should have asked the question about why the think it applies. Will look into this.

    Leave a comment:

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