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Recent content by Dilbert
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IHT on EBT settlement
Yes I think they do/did run Big Group. I wasn't part of that. As I understand it that was to challenge the concept of taxing EBTs as income in general. I wasn't part of that and gave up the fight on that side a couple of years back and settled. I've no idea what has happened to Big Group since...- Dilbert
- Post #15
- Forum: HMRC Scheme Enquiries
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IHT on EBT settlement
Yes but I have paid tax on it as though it was income. This was the agreement to settle. Now I'm being taxed a second time with IHT on a loan which wasn't a loan but was income.... I take your point on "extremely unlikely to succeed" though. This is my view too. It would help me cash flow...- Dilbert
- Post #14
- Forum: HMRC Scheme Enquiries
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IHT on EBT settlement
I had an Edge / Norla EBT and settled and had my loan written off a couple of years back. HMRC have written to me, via WTT, demanding IHT. WTT are proposing to put together a group to dispute that IHT is due and claim to have a strong argument. I've searched the forum and online to research...- Dilbert
- Thread
- ebt edge iht wtt
- Replies: 40
- Forum: HMRC Scheme Enquiries
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APN penalties - APN Penalty Appeal Group
Thanks for that. The group has extended the deadline for joining so I'm still debating this. However, they're not even sure if this exact technicality even applies to me so it does seem like a long shot.- Dilbert
- Post #9
- Forum: HMRC Scheme Enquiries
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APN penalties - APN Penalty Appeal Group
You're correct. Not seen a %. It seems when going up against HMRC the % is always low so I'm not kidding myself that winning the case is actually likely. I guess I need to work out how much it is worth to me to kick the can down the road for a year or two. Thanks for your thoughts...- Dilbert
- Post #7
- Forum: HMRC Scheme Enquiries
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APN penalties - APN Penalty Appeal Group
You're probably right. I'm not massively hopeful of overturning the decision I'll be honest. I can't fully remember the details of the case sorry. I'll try to dig it out. The main argument was that as we had appealed against the APNs in the first place so we shouldn't have had to pay the APNs...- Dilbert
- Post #5
- Forum: HMRC Scheme Enquiries
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APN penalties - APN Penalty Appeal Group
Is anybody part of the APN Penalty Appeal Group and joining in the appeal to the Upper Tribunal? I was part of the case put before the FTT to oppose penalties on non-payment of APNs (which was lost) and am considering joining the appeal to the UT. The cost is quite a bit higher than I expected...- Dilbert
- Thread
- Replies: 15
- Forum: HMRC Scheme Enquiries
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Edge EBT thread
What did you do about the indemnity in the end EdgedOut? WTT are advising me to challenge it but I'm not sure we're in a strong negotiating position. Did you just go with it?- Dilbert
- Post #1,949
- Forum: HMRC Scheme Enquiries
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Edge EBT thread
Make a decision.... Make a decision.... I agree. We're going round and round in circles here. My view, for what its worth, is that HMRC are wrong in their assessment and that our scheme was totally legitimate. Personally I'm not prepared to lie down, roll over and accept this unjust tax...- Dilbert
- Post #701
- Forum: HMRC Scheme Enquiries
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Edge EBT thread
Fighting fund / group Fighting fund / group Hi all, Received my second letter on Wednesday (2008-9 and now 2009-10). Called Michelle Booth who was very good last time but phone number, email address and website were dead today. Apparently she is still around and working for Redstone but is...- Dilbert
- Post #313
- Forum: HMRC Scheme Enquiries
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Norla EBT Loan Scheme
Contractor58, Did you ever get a definitive answer on this? I used Edge / Norla last year. I haven't received an HMRC letter (like Gizza did) but am nervous as to what might happen with that. I'm also starting a new contract soon and was going to go via the EBT route again but am having second...- Dilbert
- Post #44
- Forum: Accounting / Legal
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Edge (Norla)
Gizza / Mutur, Have you heard any more from the HMRC? What was the outcome of this? I used Edge / Norla last year. I haven't received a letter but am nervous as to what might happen with this. I'm also starting a new contract soon and was going to go via the EBT route again but am having...- Dilbert
- Post #16
- Forum: Accounting / Legal
