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Everything posted by BrahimHemdani
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Welcome Pedro! Rangers v Hamilton preview.
BrahimHemdani replied to cooponthewing's topic in Rangers Chat
I anticipate a fantastic atmosphere and early goals. I doubt Hamilton will be able to handle it and expect a comfortable victory. My only question is how many. -
Watch OldCo 'big tax case' live today and tomorrow
BrahimHemdani replied to Frankie's topic in Rangers Chat
Getting back to the case I thought the arguments, if i understood them correctly, that the Trust beneficiaries could be persons other than family therefore might be regarded as a non taxable salary sacrifice and that the payments to the Trust are exempt benefits in kind were quite strong. It was already established that those concerned had no entitlement to receive anything from the Trusts. Essentially the HMRC argument is that the whole exercise is a sham. It will be interesting to see whether common sense or the the technicalities prevail. -
Welcome Pedro! Rangers v Hamilton preview.
BrahimHemdani replied to cooponthewing's topic in Rangers Chat
I don't expect to see many changes from last week although Windlass or Forrester may start ahead of the ineffective McKay. I do think that he will want to see as many players in action as possible so I would think he will use all three substitutes fairly early and based on his comments Dodoo may get a long overdue opportunity. What I do expect is to see a higher tempo from the start embodying the philosophy of attacking when we have the ball and attacking space when we don't the have the ball. -
There is nothing knew here. We thank them for their services, albeit this season was less than satisfactory and the manner of their departure was unfortunate to say the least. Nonetheless I see no reason to do anything other than wish them every success in the future. We can now focus on a bright future for Rangers "Under New Management".
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Even going back almost 40 years, when I ran the line at England v N ireland at Wembley, I was terrified that I might give a throw in the wrong way and have it replayed a thousand times from the camera in the pit that was moving up and down beside me. These days it's a nightmare having to watch replays from all the camera angles plus the modern technology.
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Good points, of course a decision will be more controversial if it can manifestly be shown to wrong; but in the case it's all about opinions.
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Watch OldCo 'big tax case' live today and tomorrow
BrahimHemdani replied to Frankie's topic in Rangers Chat
I think that's highly unlikely, it's a complex case and the judgement will be long and will take a good length of time to prepare. However, almost certainly Lord Neuberger will be asking the others' opinions over a small sherry this afternoon and then someone will be charged with writing the (majority if that) opinion and there may also be a minority opinion as well. -
Watch OldCo 'big tax case' live today and tomorrow
BrahimHemdani replied to Frankie's topic in Rangers Chat
I think what he said was that they were making arguments not used before e.g. on PAYE, I am sure they cannot introduce new evidence. The case rests on: Issues Whether the Court of Session erred in law in reversing the specialist Tribunals below and concluding that payments of "emoluments" or "earnings", for the purposes of the Income and Corporation Taxes Act 1988 and the Income Tax (Earnings and Pensions) Act 2003, had been made by the appellant to its employees. Whether, in order for a payment to constitute earnings for PAYE and NIC purposes, it is sufficient that the payment was "derived from" work done by a particular employee and/or it "it formed part of the employee’s employment package". Whether the powers which each employee held as protector of a subtrust had the effect that the funds in that subtrust were unreservedly at the disposal of the employee and were earnings for PAYE and NIC purposes . Facts Murray Group Management Ltd established a Principal Trust for the benefit of its employees and the employees of any group company including the appellant which entered into a deed of adherence. The appellant established a number of subtrusts for the benefit of their employees families. The appellant would pay a contribution to the Principal Trustee with a direction that a sub-trust be established and funded for a family of a particular employee. The employee was appointed protector of the subtrust, and the subtrust trustee would lend the employee money that had been advanced to the subtrust from his employer. The Commissioners for Her Majesty’s Revenue and Customs determined that these payments constituted earnings for PAYE and NIC purposes and sought to impose charges to tax. The First-tier Tribunal allowed the taxpayers appeals and held that no payment of earnings had been made. The Upper Tribunal refused the Commissioners appeal. On appeal, the Court of Session held that payments of earnings for PAYE and NIC purposes had been made by the appellant. It found that the payments made to the Principal Trustee, and in due course to the subtrusts, amounted to a re-direction of income. The Court of Session granted permission to appeal to the Supreme Court on the question of whether the payments were earnings. https://www.supremecourt.uk/cases/uksc-2016-0073.html -
Watch OldCo 'big tax case' live today and tomorrow
BrahimHemdani replied to Frankie's topic in Rangers Chat
Because he's using it as an example in all manner of related cases not the Rangers case per se. -
I did referee a couple of reserve games at Ibrox and once at Morton (where I'll concede I had a nightmare) and ran the line at a few including John Greig's Testimonial, as I think is fairly well known. I couldn't have lived with the pace of the modern game.
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Yes thanks; case adjourned.
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I can see why you say that but it's the aftermath he would be worried about. He would have you to contend with for starters. Again from my experience, albeit not at that level; the referee will be concentrating as hard as humanly possible in the dying minutes to avoid GIVING a controversial decision. The fact the game ended 1-1 makes it less controversial not to give it then if he had given it and it had ended 2-1 for Celtic.
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Again, sorry to disagree. He can see the challenge with the right leg because his is right of the incident. What he may not have seen is the slight touch on the ball. But as I have argued that is irrlevant because Hill's leg came in contact with Griffiths body first, so it's a foul.
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If you look at the video from the angle behind the goal you can see quite clearly that the referee is looking straight at the incident (obviously from behind) and has an unobstructed view.
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He was looking straight at it from right to left.
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Fair enough but I disagree with them. Having viewed the video numerous times I remain of the opinion that the referee is approx 20-25 yards away and has a clear line of sight on an angle form right to left to the incident. If I had the technology I could freeze frame and draw a straight line from the referee to to the incident because there is no player between him and the incident.
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Two out of three ain't bad.
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I think we're going to have to agree to disagree here; but if you look at the video again, you will see that the referee is approx 20-25 yards away and has a clear line of sight to the incident. There is no player between him and the incident. So whatever the reason he didn't award a penalty it was not because he didn't see the incident.
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I don't think the fact that we are still debating it says anything about whether the decision was right or wrong; what it says is that it was a difficult decision.
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Almost all Rangers fans except me will say it was not a penalty and almost all Celtic fans will say it was a penalty. It would be interesting to hear the opinions of non old firm fans.
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1) OK. Agreed, Boabie posted what Rogers told the press that Hill said. 2) I am not saying that's right at all; what I'm saying is that psychologically it's easier to give a penalty at 0-0 in the 30th minute say than at 1-1 in the last minute. Because earlier in the game it's not necessarily a game or result changing decision; whereas in the last minute almost certainly it is, or at least it gives one team a good chance of winning. Can you imagine the furore from Rangers fans if he HAD given it and Celtic scored to win the game. As I said, I think it was penalty and I think he bottled it. 3) I think you disagreed that Brown should have been sent off; or was that Pete?
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Watch OldCo 'big tax case' live today and tomorrow
BrahimHemdani replied to Frankie's topic in Rangers Chat
Thornton may be boring but he has an encyclopedic knowledge and has actually argued some of the past cases that are adduced in evidence. I think he's quite convincing. I didn't hear the HMRC argument but he's really belittling their case especially on PAYE. Benefits in Kind 1) One exclusion is beneficial loans to employees which may have a charge in lieu of interest but not a benefit in kind charge. 2) What was created were 108 different trusts; but drafted in a general way with potential and replacement beneficiaries, so do not exhaust the sub-trust, so are not subject to tax because you can't say that they only exist to benefit the employee or his family. 3) Even if only members of the family could benefit; there is a possibility of double taxation. 4) The general thrust of the benefits in kind legislation is for actual benefits, which don't exist in this case. I agree that Lord Carnwarth seems to agree with most of our arguments. Court adjourned. -
Watch OldCo 'big tax case' live today and tomorrow
BrahimHemdani replied to Frankie's topic in Rangers Chat
Thornhill argues that - There's was no agreement to divert salary into the Trusts; therefore the payments are not taxable emoluments. -
Watch OldCo 'big tax case' live today and tomorrow
BrahimHemdani replied to Frankie's topic in Rangers Chat
Can they be fined for a late kick off? -
Not guilty on all three counts, your lordship. I was quoting what Boabie said Hill said. I am giving you my opinion with the benefit of my experience as a referee; IMO it was a penalty and it was an easier decision to make earlier in the game. I try to give fair opinions on match incidents from a refereeing perspective; you'll recall I said categorically that Brown should have been sent off. I doubt many Celtic fans would agree with that.