The client sought advice on equity restructure options with a focus on Capital Taxes planning, complicated by a build-up of cash from years of successful trading.
The client needed to utilise accumulated cash to qualify for business relief for Inheritance Tax purposes.
The company decided to invest the cash to qualify for business relief. The client signed an acquisition mandate with Crowe and made various offers to acquire businesses.
Crowe used the acquisition mandate as evidence of a change of intention and requested HMRC to approve business relief status, which was granted.
While waiting for HMRC clearance, Crowe worked with the client’s lawyers and, with the October 2024 budget fast approaching, assisted with settling the company’s shares into a family discretionary trust.
The trust environment provides a relatively benign and certain Inheritance Tax regime, expected to help the family with their wealth and capital taxes planning for many years to come.
The tax team was involved early in the decision-making process, and were able to obtain HMRC prompt agreed to the business relief status. The settlement transaction proceeded smoothly, with appropriate Capital Gains Tax claims submitted and Inheritance Tax reporting completed.