Posts by SD24576 28 publicly visible posts • joined 16 Jul 2012
At least in the UK, there are caps on the tax efficient schemes, some of them very small (a few grand per employee for some of the schemes) and some are larger caps on the size of the overall scheme.
A quick summary can be found here: http://www.hmrc.gov.uk/manuals/bimmanual/BIM44010.htm
I can't speak for the US of course, which is no doubt where a lot of this is happening.
Well if the company paid cash out to the same value, it would also get a tax 'break' because it would be a deductible expense (ignoring complications like NIC).
The employee will often pay tax, usually on exercise of the share option. Where it is tax exempt, such as with an EMI scheme, there are limits in place on the overall size of the scheme and conditions on the type of company and employee so the reliefs are targeted.
It may not be the average shopfloor worker in a large 'production line' manufacturing company that gets these options, but in my vaguely related professional experience the share options are often available to a very wide range of employees, especially where the company deals in services or is relatively young. Granted, the directors may get more beneficial share options than the rest of the firm, but then they'd get more cash if it was abolished, so c'est la vie.
I guess I'm just not sure the outrage is justified. There really *are* policy goals of encouraging share ownership, it's not just a plot by HMRC to collect less tax.
This isn't some tax wheeze that those terrible tax-avoiding companies are taking advantage of though - this is a specific piece of tax legislation that has been introduced (many years ago now) to encourage companies to give their staff a stake in the businesses they work for as part of their reward package.
It's completely up-front with HMRC receiving forms each year detailing exactly what's going on and with the most beneficial arrangements only available on schemes that have been specifically approved by HMRC.
Effectively the company is giving away something valuable (a stake in itself) and getting nothing in return, so it's easy to see why a government might think some tax relief is in order to encourage this behaviour.
The relief is restricted to situations where the employee has actually benefited (because the exercise price is higher than the option price) so there's limited potential for abuse.
Still waiting for Lewis Page's article backtracking on his claims of how it was all overblown and would have no significant effects. That 5km scale mark is pretty small - this is a significant and large area that has effectively been rendered uninhabitable as a result of the disaster. (Disclaimer: I still believe in nuclear power as a viable energy source, just that the triumphalist tone of his repeated articles around that time got a bit wearing)
Actually a company can have a deferred tax asset or a deferred tax liability. It's an accounting mechanism to 'smooth' out the impact of timing differences, where the tax code starts taxing things in a different way to the accounting standards. Without accounting for deferred tax, these differences would lead to unexpected volatility in your profit & loss account, so a company recognises a deferred tax asset or liability on its balance sheet, then unwinds that against the current tax differences in future years.
If the accounting and tax code differences will benefit you in the future, you can recognise a deferred tax asset; if you'll be worse off in the future, you recognise a deferred tax liability.
In this case, it looks like the company had a deferred tax asset that was no longer going to crystallise a benefit in the future due to the recently changed law - hence they reduce the asset. Cr Deferred tax asset (B/S), Dr Tax charge (P&L). It's not a cash tax or a mistake with their tax calculation for the year.
The bar is set higher for the patent box than you might think - patents filed in countries that have vacuous patent regimes do not qualify for the regime (e.g. the US is excluded) - there is a short list of qualifying jurisdictions where there is a requirement to demonstrate innovation.
The large tax and accountancy firms need to be involved in the drafting of new law because they're the only people who fully understand it and all the implications. This is also in line with HMRC's strategy of reaching out to 'stakeholders' and consulting extensively on new law. It leads to a better quality of law overall.
Finally, the finance company exemptions that Margaret Hodge refers to in the new CFC rules are a direct consequence of the government's stated desire to give the UK a competitive tax regime internationally so she is just ill informed - it's not a 'mistake' that this exemption is available. It was designed to encouraged groups to base themselves in the UK as a holding location and, in my limited experience, has worked very well - I know of several global groups that have increased their UK activity (and profits, therefore tax) as a result.
See top of page 2 for a brief mention of call quality.
To the first poster, after shelling out for a Note 2 I was a bit disappointed to hear of the Nexus 4 coming out for such a lower price point. However, after enjoying the Note 2 battery, I couldn't go back! Being able to use it inconsiderately all day and not have to worry about battery life saves so much hassle!
Mine just arrived this morning - Clove still has stock of the white ones and delivered before 9am next day for 6 quid which was pretty good. It's just doing the first charge up, but first impressions are that it looks great and the build quality feels great - the only exception to this is the battery cover when it's being prised away from the body which I was terrified of breaking. The grey colour actually looked a bit worse to my eye when I did a shop browse yesterday - the texturing almost looks like little scratches so it wasn't for me.
The manual is full of hilarious gems - "do not insert the device into your eye...", "do not bite or suck the battery", "do not store the device in a microwave or pressure cooker".
The police didn't take it seriously if you read the judgement:
"He regarded it as “non-credible”, not least because it featured the appellant’s name and, as he noted, the appellant was due to fly from the airport in the near future. Nevertheless in accordance with airport procedure he passed this “tweet” to the airport police. The airport police themselves took no action, presumably for exactly the same reason, but they decided to refer the matter on to the South Yorkshire police."
Yorkshire police then said: "there is no evidence at this stage to suggest that there is anything other than a foolish comment posted on “Twitter” as a joke for only his close friends to see.”
The problem is down to the CPS for deciding to prosecute nevertheless.
It was also interesting to read the legal justification for the original conviction and how, whilst it may seem silly to the layman, it was grounded in case law.
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