Shares, Options & Private Equity Hurdle Rewards - The Key Tax Issues

Introduction

This course will consider the tax issues relevant to shares, options and private equity hurdle rewards for UK and non-UK employees.

It will review the principal tax charges and reliefs, how to secure favourable tax treatment and the main issues on sale of the rewards.

What You Will Learn

This course will cover the following.

• Income v capital returns
• Shares v options
• Shares - vesting and forfeiture
• Principal tax issues for UK and non-UK employees
• Principal income tax charges and reliefs including:
• ITEPA - s.62 'general earnings'
• Part 7 of ITEPA - tax charges on employment-related securities and employment-related securities options
• Part 7A of ITEPA - 'disguised remuneration'
• Elections - s.431 ITEPA
• Principal social security charges and reliefs
• Capital gains tax charges and reliefs:
• Entrepreneurs' relief
• BVCA Memorandum of Understanding
• ESOPs
• EMIs
• Tax issues on sale:
• Cash
• Deferred consideration
• Earn-outs
• Courts and Anti-avoidance:
• RFC 2012 Plc (in liquidation) (formerly The Rangers Football Club Plc) (Appellant) v Advocate General for Scotland (Respondent) (Scotland) [2017]
• UBS AG v Revenue and Customs Comrs [2016]
• Tax treaties, employment income and capital gains
• Social security agreements and NIC
• Reporting