This episode is Part 2 of a two-part special, offering an in-depth look into the 'Osmond and Allen' case and exploring the complexities of Transactions in Securities.

Nick Wright, Host of The Tax Hour Podcast & Head of Corporate Tax at Jerroms Miller Specialist Tax, welcomes Ray McCann, Consultant, past president of CIOT & and previous assistant director of HMRC, along with Pete Miller, Technical Director at Jerroms Miller Specialist Tax. With a combined 90 years of experience, they provide unparalleled insights into the Transactions in Securities legislation.

In this episode, we examine the First-tier Tribunal's significant decision in Osmond & Allen v HMRC [2024] UKFTT 378 (TC), a case that highlights the rigorous application of the Transactions in Securities (TiS) anti-avoidance rules. The discussion focuses on the taxpayers’ investment in Xercise Ltd through the Enterprise Investment Scheme (EIS) and the subsequent share buybacks that prompted HMRC’s intervention.

We analyse the Tribunal’s interpretation of the “main purpose” test, its conclusion that the transactions were primarily motivated by a desire to obtain a tax advantage, and the resulting validation of HMRC’s counteraction notices. The episode also addresses the contested limitation period for HMRC assessments and the Tribunal’s view on the six-year window under section 698(5) of the Income Tax Act 2007. Finally, we consider the broader implications for tax planning and the practical lessons this case offers to investors, advisers, and tax professionals.

We hope you can join us for this informative session.

If you have any questions or need further information, please get in touch. At Jerroms Miller Specialist Tax we offer a wide range of specialist tax advice for all business tax scenarios.

A special two-part episode, offering an in-depth look into the 'Osmond and Allen' case and exploring the complexities of Transactions in Securities.

Nick Wright, Host of The Tax Hour Podcast & Director at Jerroms Miller Specialist Tax, welcomes Ray McCann, Consultant, past president of CIOT & and previous assistant director of HMRC, along with Pete Miller, Head of Corporate Tax at Jerroms Miller Specialist Tax. With a combined 90 years of experience, they provide unparalleled insights into the Transactions in Securities legislation.

In the first episode, they explore the evolution of Transactions in Securities legislation, examining modern interpretations and some of the most seminal tax cases of recent decades. They also examine the role of tribunals in ensuring transparency and compliance.

If you have any questions or need further information, please get in touch. We offer a wide range of specialist tax advice for all business tax scenarios.

In this insightful episode, Jerroms Miller Specialist Tax Director and our host, Nick Wright is joined by Michael Sherry, a leading expert from Temple Tax Chambers. They dive deep into the complex world of employment-related securities. Unpacking key tax implications, recent developments, and practical advice for both employers and employees navigating these unique financial instruments.

Michael provides invaluable guidance on structuring and managing employment-related securities, from tax planning to compliance, and offers a clear understanding of how these securities impact both personal and corporate financial strategies.

Tune in to gain expert insights into this often-overlooked area of employment law and tax.

If you have any questions or need further information, please get in touch. At Jerroms Miller Specialist Tax we offer a wide range of specialist tax advice for all business tax scenarios.

Jerroms Miller Specialist Tax Director and our host, Nick Wright is joined by Jerroms Financial Planning Independent Financial Adviser Jamie Ellis and client William Dunne.

Together they explore tax from a client's perspective, ensuring a seamless business transition for the ultimate exit, essential shareholder strategies for protecting your business, understanding management buyouts, financial strategies for protecting your business and smart inheritance tax strategies.

If you have any questions or need further information, please get in touch. At Jerroms Miller Specialist Tax we offer a wide range of specialist tax advice for all business tax scenarios.

With significant announcements expected from the Autumn Budget taking place on 30 October at ~12:30 PM, as the UK gears up for yet another budget announcement, all eyes are on the new Labour government to see how it will navigate the current economic landscape. With the cost of living crisis still biting, inflation pressures mounting, and an economy still recovering from the pandemic, the stakes are high.

Our host Nick Wright, Director, will discuss the topics that could arise, the likeliness of changes being implemented, and how you can navigate the announcements.

Our host, Nick Wright is joined by Sean Randall, one of the UK's leading experts on Stamp Taxes.

Together they explore SDLT in depth, offering their insights on recent appeals and HMRC's approach to SDLT disputes. They'll also speculate on what SDLT changes might be announced in the Autumn Budget.

Welcome back to Jerroms Miller Tax Hour! In this latest episode, Nick Wright is joined by special guest, Sharon Cooke FCA CTA, Technical Director (Tax), 2020 Innovation, to discuss predictions and insights for the upcoming autumn budget.

Sharon is a well-known speaker and consultant within the accountancy profession and speaks on all technical tax matters pertinent to accountants in practice, with a particular focus on practical application of legislation and rules.

To celebrate EO Day, we have a very special podcast for you. Our esteemed guests delve into the world of employee ownership by discussing 'Decoding EOT: Empowering your EO Business to Thrive' in our latest episode of Jerroms Miller Tax Hour.

The Employee Ownership (EO) sector is seeing significant growth, with around 1,650 employee-owned businesses already established across the UK, and this number continues to rise. Our panel will be unravelling how Employee Ownership Trusts can work for businesses in the context of the tax, legal, and policy implications and how EO can provide valuable benefits to the economy.

Nick Wright, Director, Jerroms Miller Specialist Tax, is joined by Campbell McDonald, one the UK's most experienced employee ownership experts, and Neil Palmer, Partner, Fieldfisher, a key advisor in their employee ownership team, advising 60+ clients on their successful transition to employee ownership since 2014.