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I’ve maintained all along this was a yahoo plot inside & outside HMRC. The aim was to keep Rangers in a financial straitjacket for years, unsellable & with the bank in control But there were 2 events they hadn’t planned for:-1) whyte 2)winning the BTC For me, Whyte’s plan was to force an administration & try get HMRC(& others) to settle everything owed via a CVA. And Rangers emerge debt free. It was high risk, unlikely to work & didn’t Firstly he had to force an administration. He wasn’t going to get it via the BTC or wee tax case. So he withheld tax/NI to force HMRC to the table.And it worked. But the yahoo plot had made its first error. It allowed Whyte to go for almost 6 months without paying tax/NI.(other clubs only got 1or 2 months). They had to build up sufficient debt to block a CVA because the BTC had been appealed & there was no guarantee they’d win it & indeed HMRC lost the FTTT & UTTT. Winning the BTC will now involve BDO asking all sorts of questions about penalties & whether or not they can be applied. And no doubt also asking about the length of time Whyte never paid tax. As we saw last week with bizarre panicky tweets one or two seem very edgy indeed within HMRC. 2020 should be interesting....4 points
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Recent games and discussions got me thinking https://rfcyouths.wordpress.com/2019/11/19/rangers-colts-in-irish-league/3 points
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According to the Rangers sub on Reddit we played Leicester behind closed doors today winning 3-0. Goals from Tav, Stewart and Docherty. I guess a few of the fringe players would've gotten a run out.2 points
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An interesting idea, thanks. I've no idea how feasible this is but it's an interesting discussion. I could see a pan-Irish/Scottish league happening actually, both the Irish leagues want to increase revenues and interest. There's not a massive amount in it for Scottish sides though, but combined TV deals might be attractive to broadcasters. Getting the 'swifts' into the Irish League might be a precursor to that.2 points
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What was and still is baffling - HMRC likewise never blocked or even attempted to chase Whyte when he walked on British soil again? https://www.dailyrecord.co.uk/sport/football/football-news/ex-rangers-owner-craig-whyte-being-3992415 Given the amount of info leaked by HMRC since 2012, it is rather curious that nothing about this came out in 2011/2012 ... and IMHO leads to the conclusion that it might have been withheld at the time for heinous reasons.1 point
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I have to say that I think this is a rather exuberant proposal from Rod Petrie.1 point
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Had a look at administrators proposals: So HMRC were included in the proposal for 14 million. This did not take into account the small and large (ebt) tax cases. The 14 million works out at more than 25% of the total creditors claims in the proposals. A CVA wouldn't have passed even without determining the ebt liability as HMRC would not have voted in favour it. Another reason why a CVA wouldn't have been possible is the shareholders would have had to transfer their shares to the purchaser. Politics involved this wouldn't have happened. A CVA rescues the company as a going concern, the book value of the freehold properties in the last set of accounts was £109 million. On that basis the going concern value would have been extremely high, who was really going to purchase it on a going concern valuation. However, the breakup value/forced sale value undertaken by administrators was around 4 million if I remember right.1 point
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If at all possible wrt dates, two governing bodies of the Scottish game should be able to come to an agreement to do all they can to help the national team in a bid to qualify for the Euros. We can go for the typical messageboard reaction but in the real world Scotland getting to a Finals would give Scottish football a much needed shot in the arm and for however much we don't like it,...it is where we have to ply our trade. There has even been informal views publicly expressed by both managers of us and them regards helping Scottish clubs playing in Europe. Mainly because of a lack of dates, I doubt anything will come of this unless a team were to go deep in the competition. With both teams still in the competition, I think the governing bodies should state NOW what they would provisionally look to do come next springtime...or say that they are unable to do anything.1 point
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If we reach the latter stages of Europe, would they agree to some of our games being postponed? It would help the coefficient and help Scotland's standing. I think we all know the answer, so what's good for the goose.....1 point
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Let me be as clear as I possibly can. I'm not an accountant, I don't have any of the exact figures in front of me nor the links to articles/details of those figures either, I am merely basing my assumptions on what I have memory of and my own knowledge of certain tax vehicles. We know that there were 72 EBT's that held a total estimated to be £48mil. We believe that HMRC levied a bill of £24mil that MIH/RFC disputed and as a result HMRC then imposed fines and penalties to the sum of £94mil. The reasons and legality of these penalties were and indeed still are under dispute. We've also been told that Rangers, by all and sundry, were a test case and were being used to set a precedent. First of all working backwards Rangers were NOT a test case as there had been a prior case also involving Arsenal, whom also crop up again after the fact, which would be considered THE precedent. MIH/RFC Murray were correct to dispute the £24mil bill as in situations where Trusts are established there are rules to govern this. Of course this has been updated since these events and also now include possible income tax rules. The rules at the time which haven't changed and from experience; Trust containing dividend < £1k are taxed at 7.5% on the first £1k and thereafter taxed at 28%. Trust containing dividend > £1k are taxed at 38.1% on the first £1k and thereafter taxed at 45%. At no point in any of the subsequent calculations does the tax due ever reach 50% or above. Therefore the 50% figure as you can see is incorrect in ALL cases of dividend in trust even after the change. If we can accept that these Employment Benefit Trust vehicles were, at the time of operation, not subject to income tax then it follows that up until April 2011 they could be recovered/transferred at their previous tax rates although there was a degree of uncertainty, with regards to that, at that time. This degree of uncertainty is what I believe Murray was partly disputing remember that what I am saying is valid with regards to the date where the HMRC claim is established circa 2009-11. The uncertainly aspect, as I remember, was whether or not these new rules would be retrospectively applied. Now Murray could never be accused of altruism but he is right to dispute the HMRC claim a) to allow trustees and employees to make arrangements for transfer, and b) at the time EBTs weren't subject to income tax, not until the SC ruling 2017, and even under these new rules income tax/company tax is only due when funds are 'earmarked' i.e set for withdrawal/transfer*. Now I stick to my previous assertion that Murray had some idea that income tax rules might be retrospectively applied and that he was attempting to clear the debit, at the lower rate, circumventing these probable new tax rules quickly before legislation had been put in place. He NEVER refused to pay HMRC, in fact he offered £9mil plus £10mil over a number of years which IMO is much closer to the correct liability than HMRC's £24mil claim, therefore their step of applying fines and penalties was NOT only inaccurate but was also UNPRECEDENTED! The argument, we [rangers supporters] have always maintained skulduggery, playing out before our very eyes is, not that the HMRC assertion that income tax was due re: the SC case, but that the outlandish figure of £94mil was a gross misrepresentation of the debit Oldco owed on the part of HMRC and that claim effectively hamstrung Oldco as toxic is not only correct but it is also an absolutely unprecedented tragedy of an overarching government body that requires nothing less than a full public enquiry. * I'm not sure if transferring 'earmarked' funds is subject to income tax/company tax as I haven't looked at them since the rules were amended.1 point
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Reading the above, it seems unprofessional. There's a personal/collective edge? HMRC did not miscalculate the original tax bill, the miscalculation came in the draconian and aggressive penalties triggered by EBTs. EBTs were legal. Thus, no miscalculation of figures on original tax owed; however, massive miscalculation on the law - miscalculate ANYTHING????????1 point
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It always did appear to be orchestrated. None of that is news. If you're just reaching that conclusion then that's fine. Some of us have been living with that realisation for many years. Rangersrab, for example, has been calling out certain politicians, bankers and others for years. I've been through it all. I just don't feel like wasting more mental anguish on it. The time for establishing those guilty of it was earlier this decade. In my totally uninformed opinion, if it hasn't happened by now, it's not going to happen. They even managed to (deliberately?) cock up the trials of Whyte and D&P. It's now part of the Rangers story and there's little or nothing we can do to change it.1 point
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The threat of millions of pounds litigation & horror stories had been going on since 2008 No one was touching us Pressure on the bank etc It’s ok saying that HMRC were owed just £68m, the point is that Huge parts of that debt was caused by Whyte etc - the Phantom bill was a catalyst for everything that happened to us indirectly or directly That’s my point Had it been administered properly then there’s a chance SDMs £10m settlement offer may have been accepted etc It’s a debate on Ifs & Buts, there’s certainly no doubt in my mind we were hamstrung because of it1 point
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OK - it seems more information is starting to leak out (including possible letters to former players) and HMRC's claim may indeed be reduced to circa £20m as 'The Times' has noted overnight. IF that's correct (and it remains a big if right now) and the HMRC claim is reduced to £20m then the oldco would still have had a debt of at least £40m in 2011 (i.e. the time of the sale to Whyte). That's a lot but would have been manageable for sure and was certainly a better situation than what arose from admin. However, we arguably still would have been owned by Whyte. With that in mind, it's important to note, because of the BTC (and the financial crash of that period), Murray/LBG wanted a sale asap no matter if it was £20m claim, £94m claim or even if Murray had managed to settle (which looks like what should have happened). Ultimately the sale to Whyte took place before full info of what HMRC wanted was known (publicly at least) - partly because we were still insisting EBT's weren't subject to tax. Nevertheless, questions remain over HMRC timelines and actions. At what point did they know how much they'd be claiming? Why did they get their sums so wrong? Who was responsible? Should a CVA have been agreed? And, of course, the £68.3m question, could/should they have come to a settlement before 2011, making the club more attractive to other interested parties, perhaps avoiding a sale to Whyte? Lots of questions then and very few answers. In fact, I doubt we'll ever get answers and the best outcome will be an increased dividend for creditors of the oldco. All things considered the motivation of many parties is difficult to outline from MIH to LBG to HMRC to Whyte to Green to other clubs to the SFA to the media and to the politicians. What is for sure, an institution fell apart because of their actions and the genuine people that did lose out - from shareholders to creditors to fans, are the victims and that should never be forgotten when it comes to asking for contrition.1 point