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Obadiah

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6420 posts
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#46
10/11/2018 at 07:08

Quote Quote by RichardCheatham - City AFC on 09/11/2018 at 23:42
I’d cut down on the sauce if I were you Obi.

Save your googling for porn and how to spell words like barracuda.


Looking up preferences in insolvency legislation is far more interesting. I take it you have now read what I posted and understand why the administrator would pursue the Allams for any money paid off the debt from the final parachute payment.

Its all a bit academic if essexgull is right about the offers. Assem will let Ehab keep the club, especially if we avoid relegation. 

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potential

2263 posts
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#47
10/11/2018 at 07:47

If junior is allowed to keep his trainset to the end of the season, the parachute money will keep things ticking over. And when it's gone? Papa sells for what he paid for it, and the new owner pays off the revenue to halt the winding up order. All a bit deja vu.

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RichardCheatham - City AFC

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#48
10/11/2018 at 08:50

Quote Quote by Obadiah on 10/11/2018 at 07:08


Looking up preferences in insolvency legislation is far more interesting. I take it you have now read what I posted and understand why the administrator would pursue the Allams for any money paid off the debt from the final parachute payment.

Its all a bit academic if essexgull is right about the offers. Assem will let Ehab keep the club, especially if we avoid relegation.


I had a quick look but frankly the example used has very little correlation to the Allamhouse case plus if there was any significant weight behind that section the author would have used a recent case as an example. They didn’t.

I have been in court where property owners transferred assets to a shell co they owned at no value and put their business in administration the following day. Defrauding creditors. Despite pointing this out to the judge, what do you think actually happened?

The Allams are home free and their only regret, aside from getting involved in the first place, is not selling after the Wendies got spanked in public.

This might be incorrect but I’m sure I read Wigan was sold at £20m, which included the stadium and training facilities. Where do you think 5e value for Hull City lies? Let’s say it’s £15m Badtongue. They can keep the ?Harry clause and make that without any agro, plus get the tax whizz.

As they say, the sun sometimes shines on a dogs arse so a sale is always possible. Administration is probable. 

Bunkers Hill - See you in the next life 

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Obadiah

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#49
10/11/2018 at 09:42

Quote Quote by RichardCheatham - City AFC on 10/11/2018 at 08:50


I had a quick look but frankly the example used has very little correlation to the Allamhouse case plus if there was any significant weight behind that section the author would have used a recent case as an example. They didn’t.

I have been in court where property owners transferred assets to a shell co they owned at no value and put their business in administration the following day. Defrauding creditors. Despite pointing this out to the judge, what do you think actually happened?

The Allams are home free and their only regret, aside from getting involved in the first place, is not selling after the Wendies got spanked in public.

This might be incorrect but I’m sure I read Wigan was sold at £20m, which included the stadium and training facilities. Where do you think 5e value for Hull City lies? Let’s say it’s £15m Badtongue. They can keep the ?Harry clause and make that without any agro, plus get the tax whizz.

As they say, the sun sometimes shines on a dogs arse so a sale is always possible. Administration is probable.


I bet Steven George Emsley thought he was ok when he paid £218,000 to his other companies. He ended up being disqualified from acting as a company director for 6 years.

According to this the Allams get no tax relief from putting Hull City into administration.

https://www.taxation.co.uk/Articles/2015/ 06/16/333249/company-loans

Hull City is worth what someone pays for it.

If there's no buyer then Ehab could make £3 or £4 million profit a year as we settle into mid-table respectability. It would earn him far more than putting the club into administration. 

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Hulltim8 City AFC

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#50
10/11/2018 at 10:07

Quote Quote by RichardCheatham - City AFC on 09/11/2018 at 23:42
I’d cut down on the sauce if I were you Obi.

Save your googling for porn and how to spell words like barracuda.

"he’d never play in the 1s, such is there footballing knowledge." You could do with spending time learning when to use there or their. And when to use commas.

2005 Labour got 355 seats from 35.2 % of the vote on a 62.4% turnout. 2015 Tories got 331 seats from 36.9% of the vote on a 661% turnout. Left wing fannies moan the second one is sooooo unfair and we need electoral reform. But didn't utter a peep,about the first one. 

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Hulltim8 City AFC

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#51
10/11/2018 at 10:16

Quote Quote by essexgull on 08/11/2018 at 17:08


Here is what I've heard allegedly, Garrrry old bean, take it or leave it...

Both buyers are tin-pot. They've offered around a quarter of what the Allans have valued the club at (ca. 7-9 million). The Allans are now prepared to take 25 million for the club, as Assam wants out asap, but neither prospective buyer can afford it and Duffen's mob have offered some sort of delayed payment scheme, that the Allans rightly don't trust, as their 'due diligence' offering for this purchase is some tiny Arabic bank offering them a future credit line - pretty much the same as you or I offering our Amex statement which shows our total spending limit. Neither buyer can show viable means to fund the club for the £4-5 million it is costing a year, so debt will be loaded onto the club even if it is sold debt-free. There will not be any great investment in the team from either buyer, despite promises.

The issue for the Allans is that they will 'make' more money putting the club in administration, as Cheats surmises, than selling it for £10 million and potentially getting the flak anyway for it later down the road. Basically, my source guesses that if they don't get the minimum 25 million, in which they will loudly announce as selling the club at a huge loss to follow the demand of the people of Hull, they will make the money back taking the parachute payment and putting the club in administration in summer 2019, having it run by as cheap an accountant as possible, Martyn Fish style and using the 'loss' as a tax write-off.

Senior Allan is angry and reproachful at Junior for rejecting serious bids when he was ill, stating that they could have walked away in profit, with his legacy to the city still intact.

Doesn't bode well for the future.


ESSEX GULL


Fascinating to know how someone with supposedly no connection to Hull or Hull City is so au fait with the goings on at the club. Are the taxi drivers in Norway exceptionally well informed? Are the financial goings on a major topic in the bars and cafes there? 

2005 Labour got 355 seats from 35.2 % of the vote on a 62.4% turnout. 2015 Tories got 331 seats from 36.9% of the vote on a 661% turnout. Left wing fannies moan the second one is sooooo unfair and we need electoral reform. But didn't utter a peep,about the first one. 

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RichardCheatham - City AFC

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#52
10/11/2018 at 10:17

Big yawn their Tim.

As I always say, post about grammar or choice when yo7 have nothing sensible to add.

Wanker

Bunkers Hill - See you in the next life 

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RichardCheatham - City AFC

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7172 posts
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#53
10/11/2018 at 10:37

Quote Quote by Obadiah on 10/11/2018 at 09:42


I bet Steven George Emsley thought he was ok when he paid £218,000 to his other companies. He ended up being disqualified from acting as a company director for 6 years.

According to this the Allams get no tax relief from putting Hull City into administration.

https://www.taxation.co.uk/Articles/2015/ 06/16/333249/company-loans

Hull City is worth what someone pays for it.

If there's no buyer then Ehab could make £3 or £4 million profit a year as we settle into mid-table respectability. It would earn him far more than putting the club into administration.


No idea who Emsley is and the link goes through to Larry Laffer, who might do well on here (or is it, hear Tim) as we could do with some light relief.

Straws and clutching Obi so I’m not wasting my time clicking on your links anymore. It’ll all play out and we can have a nice thread saying I told you so, as long as we all spend four years at Oxford first studying English so our submissions meet the literary standards set by the resident online editor, scooptim8.

Happy googling and all that. I’m off to post some bollocks about how we will win 0-3 at Birmingham 

Bunkers Hill - See you in the next life 

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Hulltim8 City AFC

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#54
10/11/2018 at 11:01

Quote Quote by RichardCheatham - City AFC on 10/11/2018 at 10:17
Big yawn their Tim.

As I always say, post about grammar or choice when yo7 have nothing sensible to add.

Wanker


Like you did with Obi? Presumably yo7 (sic) had nothing sensible to add.
BTW it is 1sts or firsts. 1s is a contraction of ones.

Wanker

2005 Labour got 355 seats from 35.2 % of the vote on a 62.4% turnout. 2015 Tories got 331 seats from 36.9% of the vote on a 661% turnout. Left wing fannies moan the second one is sooooo unfair and we need electoral reform. But didn't utter a peep,about the first one. 

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Hulltim8 City AFC

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#55
10/11/2018 at 11:03

Quote Quote by RichardCheatham - City AFC on 10/11/2018 at 10:37


No idea who Emsley is and the link goes through to Larry Laffer, who might do well on here (or is it, hear Tim) as we could do with some light relief.

Straws and clutching Obi so I’m not wasting my time clicking on your links anymore. It’ll all play out and we can have a nice thread saying I told you so, as long as we all spend four years at Oxford first studying English so our submissions meet the literary standards set by the resident online editor, scooptim8.

Happy googling and all that. I’m off to post some bollocks about how we will win 0-3 at Birmingham


Your mission to be the biggest wanker on here is coming along admirably. 

2005 Labour got 355 seats from 35.2 % of the vote on a 62.4% turnout. 2015 Tories got 331 seats from 36.9% of the vote on a 661% turnout. Left wing fannies moan the second one is sooooo unfair and we need electoral reform. But didn't utter a peep,about the first one. 

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Obadiah

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6420 posts
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#56
10/11/2018 at 11:27

Quote Quote by RichardCheatham - City AFC on 10/11/2018 at 10:37


No idea who Emsley is and the link goes through to Larry Laffer, who might do well on here (or is it, hear Tim) as we could do with some light relief.

Straws and clutching Obi so I’m not wasting my time clicking on your links anymore. It’ll all play out and we can have a nice thread saying I told you so, as long as we all spend four years at Oxford first studying English so our submissions meet the literary standards set by the resident online editor, scooptim8.

Happy googling and all that. I’m off to post some bollocks about how we will win 0-3 at Birmingham


Shame my link didn't work. What Laffer said was that the Allams would get no tax relief from writing off the debt.

Here it is in full:

If X Ltd impairs the debt in its books (or otherwise writes off or releases the debt), the resultant debit in its profit and loss account will reduce its profits available for distribution.
The recent dividends would have been lawful only if the company had available accumulated realised profits to make those dividends. In doing so, the directors should have considered the latest statutory accounts (under CA 2006, s 836 and s 837) as well as the fortunes of the intervening period since (under common law and possibly s 836 and s 838).
In both cases, account should have been taken of the need for any impairment of the amount owing by Z Ltd.
If those dividends were unlawful, any person receiving a dividend that knew (or should have known) that it was unlawful is liable to repay it to the company (under common law and CAA 2001, s 847). As such, any amount so received is held on constructive trust for the company.
This is discussed in HMRC’s Company Taxation Manual at CTM15205, which goes on to say that the amount is to be regarded as a loan to a participator. That may not be correct in a simple case; the amount cannot, in the first instance, be received both as trustee and as debtor.
However, once the recipient has applied the funds so received for their own purposes, it is the inevitable conclusion that a loan or advance to a participator has been made, such that a charge does arise under CTA 2010, s 455 for a close company.
The other issue is then the corporation tax treatment of the impairment (or write-off or release).
If X Ltd and Z Ltd do not have a connected companies’ relationship, X Ltd will obtain corporation tax relief for its accounting debit (almost certainly it will be a non-trade loan relationship deficit). If the companies do have such a relationship, then no such corporation tax relief will be available for X Ltd, by virtue of CTA 2009, s 354.
Likewise, Z Ltd can be taxable only on any corresponding accounting credit that it may have if the two companies do not have a connected companies’ relationship, by virtue of s 358.
However, it does not follow that Z Ltd must make any entry in its accounts simply because X Ltd has impaired the amount owed in its own accounts. Indeed, all the time that Z Ltd continues to legally owe the money to X Ltd, it should continue to recognise the liability in its accounts.
That may mean that, even if the companies do not have a connected companies’ relationship, there is no taxable amount for Z Ltd, despite tax relief being available for X Ltd.
The two companies will be regarded as having a connected companies’ relationship if one controls the other or if they are both under the control of the same person (s 349).
For this latter purpose, HMRC used to consider that two companies were connected if they were under the control of the same single person. HMRC now acknowledge – in the Corporate Finance Manual at CFM35120 – that “person” includes “persons” (by virtue of IA 1978, s 6©), but only (HMRC say) if they can be expected to act in concert.

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RichardCheatham - City AFC

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#57
10/11/2018 at 14:02

Divis are not part of the equation in the “Allam case” Obi.  

Bunkers Hill - See you in the next life 

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Obadiah

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#58
10/11/2018 at 16:56

Quote Quote by RichardCheatham - City AFC on 10/11/2018 at 14:02
Divis are not part of the equation in the “Allam case” Obi.


No but this bit of what I copied is

The other issue is then the corporation tax treatment of the impairment (or write-off or release).
If X Ltd and Z Ltd do not have a connected companies’ relationship, X Ltd will obtain corporation tax relief for its accounting debit (almost certainly it will be a non-trade loan relationship deficit). If the companies do have such a relationship, then no such corporation tax relief will be available for X Ltd, by virtue of CTA 2009, s 354.

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NationalTiger

Administrator
First used 09/01/17

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Hull City

#60
10/11/2018 at 20:03

Quote Quote by Obadiah on 08/11/2018 at 09:08
If the Allams walk off with the parachute payments of £34 million and put the club into administration there's a good chance they'll end up disqualified as company directors and all for a £6 million reduction in their tax bill.


Obi, the flaw in your argument is this; the Allams don't see the £34m as the football club's money (you're thinking like a fan) they see it as theirs.

They're getting that £34m payment (and anything else extra for that matter) come what may. Selling the club, keeping the club, whatever. They're getting it. Not Hull City.

So you just tell me when they fuck off and then finally this club can begin rebuilding itself. 

Now then... 

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NationalTiger

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Hull City

#61
10/11/2018 at 20:24

Quote Quote by Obadiah on 10/11/2018 at 09:42
If there's no buyer then Ehab could make £3 or £4 million profit a year as we settle into mid-table respectability. It would earn him far more than putting the club into administration.


Really trying hard not to have a pop at you Obi, but this a fallacy. The very fact we are looking extremely likely to be in the Third Division in a few short months only adds weight to the argument.

If only it was that easy. 

Now then... 

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