Half Day Course                                                      

Dates

12 December 2008
19 January 2009
12 June 2009
11 December 2009
          
Course Overview

This course is intended for those involved in MBO transactions who need to have an understanding of the taxation pitfalls and opportunities that arise. The course will focus in particular on the taxation treatment of the managers’ shares and the potential problems that could arise following Schedule 22 Finance Act 2003.

Course Content

 The target business
Acquisition of trade and assets or shares in target
Possible tax charges if target company acquired
Preserving trading losses

 Taxation of Venture Capitalist Funding
Tax treatment of debt and equity
Taxation of share buy-backs
Taxation of share sale

 The tax treatment of managers’ shares
Interest on money borrowed to buy shares
Capital gains treatment on eventual sale – business taper
Potential income tax charges as a result of Schedule 22 Finance Act
  2003
Complying with the “safe harbour” conditions in the memorandum of
   understanding between BVCA and Inland Revenue
Structuring ratchets to avoid income tax charges on the managers

 Using EMI options to recruit, retain and incentivise key staff
Qualifying companies
Conditions to be satisfied by employees
Exercise conditions, forfeiture, restrictions
Disqualifying events