Farhad Moshiri

[bizzaro]

Personally I think the inference from The Blue Union is that a Board containing Bill, Jon Woods, Mr Moshiri's representative and our CEO Robert Elstone does not represent sufficient change, or at least the change they expected when Mr Moshiri's purchase of shares was announced.

Oh Esk. Where do we even start with these things???

Remember. You're talking to the person presently obssessed with trying to work out every facet of what Mr Moshiri is planning for us.

As you well know.

 

[bizzaro]

Incorporating a company in the Isle of Man has certain advantages for an investor, and in the case of Mr Moshiri:

• Legal system based on English common law
• no general capital gains tax, turnover tax or capital transfer tax, and there are no stamp duties
  
• no requirement to audit accounts as turnover in the holding company will be less than £5.6 million and has less than 50 employees
• nominee directors allowed, single director also allowed
• compared to other offshore jurisdictions IoM is cheap
• he has existing assets inside other IoM Holding companies

There is no disadvantage to Everton at all in him holding his interest in Everton in an IoM company.

Probate could cause some issues in the event something unfortunate happens. Probate would not materially impact Everton if the deceased party owned the company through an IoM company. Since the company would continue as a going concern regardless until any probate decisions had been taken.

Isn't that one advantage?

 

[bring the ghost on]

From a dividend perspective the IOM company doesnt achieve anything that a UK company cant- you can pay dividends out of the football club tax free in either case.

The tax reason is more like to be how he is taxed on a future sale of shares in the club (no tax in IOM).

A good point, and I think the implication here is that Moshiri will always have an eventual sale in mind, however I have always understood that inter-corporate dividends are tax free, thus there is actually a tax advantage on the dividend point (he would pay tax on any dividends paid to him as a personal shareholder).

 

[bizzaro]

I think there's a lot of edgy people wondering just what Moshiri's game is, tbh.

Cant blame people for wondering out loud...they're just filling the gaping vacuum where a plan should have been announced in the first week or so after he took effective control.

First rule of control: manage the message or have it managed for you.

I think it's a nudge in the ribs of Moshiri to remind him that we've had enough of being kept at arms length at this club.

Dave dave dave.

You know I'd be saying -

WISH WE WERE VILLA

All over the show if there was any foreseen issues. Think that some people in BU have fired their guns far far far too early here. This "need for change" thing just looks silly.

 

[The Esk]

Probate could cause some issues in the event something unfortunate happens. Probate would not materially impact Everton if the deceased party owned the company through an IoM company. Since the company would continue as a going concern regardless until any probate decisions had been taken.

Isn't that one advantage?

The ownership of the IoM company is most likely to be another offshore company - I really do not see probate as an issue. I know many people who if they died tomorrow their business interests would continue with no interruption whatsoever.

One of the first things an individual who accumulates wealth, looks at is succession planning - Mr Moshiri and his advisors will be well versed in that respect

 

[bring the ghost on]

Probate could cause some issues in the event something unfortunate happens. Probate would not materially impact Everton if the deceased party owned the company through an IoM company. Since the company would continue as a going concern regardless until any probate decisions had been taken.

Isn't that one advantage?

Either way, Everton FC will continue as a going concern and the shares (either held directly in Everton or remotely through a HoldCo) will be dealt with in the usual manner under probate, so there is no real advantage or disadvantage either way.

 

[The Esk]

A good point, and I think the implication here is that Moshiri will always have an eventual sale in mind, however I have always understood that inter-corporate dividends are tax free, thus there is actually a tax advantage on the dividend point (he would pay tax on any dividends paid to him as a personal shareholder).

When you buy a company or any asset a high net worth individual will always purchase it in a structure that allows for the most efficient transaction at a later date for both buyer and seller.

 

[bizzaro]

The ownership of the IoM company is most likely to be another offshore company - I really do not see probate as an issue. I know many people who if they died tomorrow their business interests would continue with no interruption whatsoever.

One of the first things an individual who accumulates wealth, looks at is succession planning - Mr Moshiri and his advisors will be well versed in that respect

Hmmm.. yeah guess you're right when you are ploughing £200 million into an entity you are buying.

 

[bring the ghost on]

When you buy a company or any asset a high net worth individual will always purchase it in a structure that allows for the most efficient transaction at a later date for both buyer and seller.

Correct, I was just pointing out that that is not the only reason for using the corporate vehicle (dividend tax advantages too).

 

[davek]

DaveK will be behind it, look at his twitter with the food bank and FSF stuff, and his campaign on here regarding Moshiri, him and watched toffee,
never been seen in the same room

...I'm on twitter?

Lol.

 

[James]

A good point, and I think the implication here is that Moshiri will always have an eventual sale in mind, however I have always understood that inter-corporate dividends are tax free, thus there is actually a tax advantage on the dividend point (he would pay tax on any dividends paid to him as a personal shareholder).

That's true if he was a UK resident but as he's resident in Monaco he wont pay any personal income tax on dividends paid by either a UK company or one based in IoM.

From a corporate tax perspective the receipt of dividends paid by the club by the holding company is unlikely to be taxed under either the UK or IOM scenarios. Equally there will be no withholding tax levied on any onward distribution to Mr Moshiri in both cases.

 

[bizzaro]

...I'm on twitter?

Lol.

Need your address!

I think its abit odd that people expect Mr Moshiri to be 'micromanaging' EFC.

Thats why he's delegated to his proxy on the board isn't it? Plus obviously your mates Bill Kenwright, Jon Woods and Robert Elstone who are delegated to also.

Why is everyone expecting Moshiri to be making decisions about all the small stuff?

 

[davek]

Dave dave dave.

You know I'd be saying -

WISH WE WERE VILLA

All over the show if there was any foreseen issues. Think that some people in BU have fired their guns far far far too early here. This "need for change" thing just looks silly.

It's probably as the esk says: that they're referring to the old guard staying on. I'd also say, however, that's exacerbated by a lack of information coming forth from him.

 

[davek]

Need your address!

I think its abit odd that people expect Mr Moshiri to be 'micromanaging' EFC.

Thats why he's delegated to his proxy on the board isn't it? Plus obviously your mates Bill Kenwright, Jon Woods and Robert Elstone who are delegated to also.

Why is everyone expecting Moshiri to be making decisions about all the small stuff?

...not small stuff, a vision - some broad brush strokes. From that BU tweet today you can see the sort disgruntlement that can begin to fester.

 

[bring the ghost on]

Why is everyone expecting Moshiri to be making decisions about all the small stuff?

I think people are expecting him to make decisions about the stadium, funding player transfers and commercial strategy. Even though Moshiri won't sit on the board, Ryazantsev will essentially be his mouth piece on these big points (and will have some autonomy on smaller issues).