Becky Rees

Becky joined Parisi Tax as a partner in 2011 having had over 10 years' experience at a large national law firm. Her clients rely on her clear and straightforward approach to tax and they value her ability to give clear recommendations. Clients appreciate the fact that she works tirelessly to get them the right result. Chambers quotes clients as noting that she provides "exceptionally clear and pragmatic advice." She specialises in all tax aspects of M&A work including seller and buyer tax planning, advising on tax deed and warranties and advising on employment related securities. She advises on debt restructurings and other group reorganisations. She specialises in EIS and SEIS investments offering creative solutions to challenging problems. She has a wealth of experience in designing and implementing executive share incentive plans. Becky also advises on property transactions, including VAT and SDLT structuring, advice on development and acquisition structures and TOGCs.

Practice Area

Panel

  • Contributing Author

1 Contributions by Becky Rees

UK Share Incentives for Private Equity-Backed Companies: Control Tests, EMI/CSOP, PAYE/NICs, BADR and Alternative Equity Structures
PRACTICE NOTES
UK Share Incentives for Private Equity-Backed Companies: Control Tests, EMI/CSOP, PAYE/NICs, BADR and Alternative Equity Structures
Private equity backed companies The challenges encountered by private equity backed businesses when deploying shares to motivate staff broadly mirror those experienced by other organisations. Nonetheless, these entities have certain distinctive characteristics that warrant attention. Private equity deals are commonly arranged through a parent company that, in turn, owns shares in the trading company. It is also frequent to see one or more intermediary holding companies positioned between the top holding entity and the trading company. The ultimate owners of the holding company, alongside management investors, will typically comprise one or more partnerships or investment funds. Control: Qualifying to grant tax-advantaged options Depending on the stake held by a private equity investor, and the control rights conferred by the company’s articles of association and any investment agreement, the company that issues the shares (the 'issuing company') may be regarded as controlled by another company. This presents a difficulty where the issuing company intends to run tax-advantaged enterprise management incentives (EMI) options and company share option plan (CSOP) options (see: EMI and CSOPs below). By way of illustration, for EMI options, paragraph 9 of Schedule 5, Part 3 to the Income Tax (Earnings and Pensions) Act 2003 is relevant in particular...
Share Incentives
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