Edge EBT thread

[david se london]

To all, TheDandy,

if I have broken the rules on disclosing any information re 'the group' to the public thread, mea culpa, not intentional, and only with an interest in airing a precis of the 2 approaches; Im not sure of any material errors committed.

I have certainly not aimed at giving an opinion, thus sticking to my privately stated aim to you. Obviously Im a new guy on the block & indeed 'am on the fence' re which of the 2 apparent ways forward to take.

Best to take this offline and for me to try to better understand how the group plans to determine what the best approach is, which isn't clear to me. No point polluting the public thread with email ping pong.

I would expect that the merits of both were very clearly spelled out to all concerned before any decision was taken. I repeat there is absolutely no point being proprietorial.

nb: It is unfortunate that the thread seems to state on page one (updated 13/12/13) and also 58 that there are two groups - is this true still, or should we chastise (!) GoneSouth and channel all comms through TheDandy?

What a minefield

[varunksingh]

QC

if anyone wants a QC then it seems like he is the man
The Legal 500 > Pump Court Tax Chambers (Chambers of Andrew Thornhill QC) > London, ENGLAND > Lawyer profiles > Andrew Thornhill QC

All cases won against HMRC regarding EBT - Dextra, Sempra and Rangers have/are being represented by him. I am not saying we need a QC as I agree with Saleos what should be done at this point. Just pointing out who I found out to be the best QC for these type of cases

[Ron Swanson]

Precis Of 2 Groups

To all, TheDandy,

if I have broken the rules on disclosing any information re 'the group' to the public thread, mea culpa, not intentional, and only with an interest in airing a precis of the 2 approaches; Im not sure of any material errors committed.

I have certainly not aimed at giving an opinion, thus sticking to my privately stated aim to you. Obviously Im a new guy on the block & indeed 'am on the fence' re which of the 2 apparent ways forward to take.

Best to take this offline and for me to try to better understand how the group plans to determine what the best approach is, which isn't clear to me. No point polluting the public thread with email ping pong.

I would expect that the merits of both were very clearly spelled out to all concerned before any decision was taken. I repeat there is absolutely no point being proprietorial.

nb: It is unfortunate that the thread seems to state on page one (updated 13/12/13) and also 58 that there are two groups - is this true still, or should we chastise (!) GoneSouth and channel all comms through TheDandy?

What a minefield

I for one appreciate the precis - it does articulate the differences in laymans terms.

If the precis is accurate, then the logical flow (to me anyway) - is Saleos' proposal then TheDandy proposal and then the FTT representation costs.

Regardless of that - the optimal solution has to be ONE GROUP and not TWO

[bstar1]

I for one appreciate the precis - it does articulate the differences in laymans terms.

If the precis is accurate, then the logical flow (to me anyway) - is Saleos' proposal then TheDandy proposal and then the FTT representation costs.

Regardless of that - the optimal solution has to be ONE GROUP and not TWO

Agree

[cerner]

All,

there look to be 2 contrasting approaches on the table

1/ TheDandy, who to his credit has independently contacted a tax savvy barrister (not QC) and identified an approach that would determine a contemporary 'legal opinion' on the Edge EBT scheme (@15K total cost) and then leaves open what to do next, with no quoted costs to go forward for the engagement with HMRC that would almost certainly follow. Initial cost pp will depend on how many folk take up this option, current quotes might be @600-700pp

2/ Saleos (credentials to be verified but looks bonafida) offering a more holistic option for 750pp that dispenses with getting legal opinion as he considers he is sufficiently in the loop already, with 'very similar' in-flight cases in his tax advisor portfolio and recent access to QC opinion. This option to include ongoing engagement with HMRC on groups' behalf & 'admin' aspects included.

Both stop where serious litigation (FTT) might kick in.

I hope this is a reasonably accurate if simplistic précis of the two offers.

Personally I wouldn't pay to join a group for anyone to just tell me if I have a fighting chance or not.
I already know I have a fighting chance as the rangers court victory showed.

Saleos group which has the complete package seems better option.

[DonkeyRhubarb]

if anyone wants a QC then it seems like he is the man
The Legal 500 > Pump Court Tax Chambers (Chambers of Andrew Thornhill QC) > London, ENGLAND > Lawyer profiles > Andrew Thornhill QC

All cases won against HMRC regarding EBT - Dextra, Sempra and Rangers have/are being represented by him. I am not saying we need a QC as I agree with Saleos what should be done at this point. Just pointing out who I found out to be the best QC for these type of cases

Yep, he's got an excellent rep. Would be happy to have him batting for me at a tax tribunal. He don't come cheap though.

[Ron Swanson]

Self Representation

Personally I wouldn't pay to join a group for anyone to just tell me if I have a fighting chance or not.
I already know I have a fighting chance as the rangers court victory showed.

Saleos group which has the complete package seems better option.

Just a question - are you going to be representing yourself and would you be doing that if it went to FTT

[K12AN]

He don't come cheap though.[/QUOTE]

He is representing Rangers at the moment - so the outcome of that will be interesting

[cerner]

Just a question - are you going to be representing yourself and would you be doing that if it went to FTT

No, I'll join a group with a group lawyer representing.

[Saleos]

Andrew Thornhill QC

I have used Andrew before and he would be one of those I'd suggest considering if it becomes necessary.

Whoever said he won't be cheap though isn't lying. Six figures for just the FTT.

If it helps, in my proposal I say that I have access to the opinions of two silks on arrangements very similar to Edge. One is from Thornhill the other another QC in his chambers.

Yep, he's got an excellent rep. Would be happy to have him batting for me at a tax tribunal. He don't come cheap though.