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Ryan D •
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Ryan D •
@Ryan_D81
$BTC $CHEX $LINK $MSTR $STRC | @OfficialFPL @NorwichCityFC | 🐎 | #RWA is the future of TradFi
Katılım Mayıs 2020
1.2K Takip Edilen291 Takipçiler

@Ford_Nick Salt and pepper. Pair it with béarnaise sauce, a decent red wine and a few light vegetables. This one from my grill earlier this evening 🔥

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Come home
John Townley@johntownley11
Lewis Dobbin, who has scored eight goals for Preston this season, says that his long-term goal remains to play for #AVFC. "I went with the aspirations to play for Villa. That's always my goal, that's always the long-term goal," he told @GHodgsonSport. birminghammail.co.uk/sport/football…
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April Fools'. There will be no need for an apology this time @NorwichCityFC!
Reform UK@reformparty_uk
Carrow Road awaits. 🏟️ 👀
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🤔 𝙋𝙊𝙄𝙉𝙏𝙎 𝙋𝙍𝙀𝘿𝙄𝘾𝙏𝙄𝙊𝙉 🔮
Are you going for 0️⃣, 1️⃣ or 3️⃣ points❓
How do you think we’ll perform❓⚽️
#NCFC | Win with @WingfieldHelp 🤝

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@Champchatpod24 As an Ipswich fan, I am shit-scared of losing to Norwich on April 11th, as they are far superior and bullied us for ~15 years. Please win so we don’t have to start with the counselling again 😭😭😭🙏🙏🙏
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Ipswich Town, with eight games still to play, are currently just two points behind second-placed Middlesbrough. 📊
Unbeaten in seven, winning four, will Kieran McKenna's men clinch automatic promotion? 🤔
Send us your thoughts, Tractor Boys fans! ⬇️
#ITFC

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@masonhurst18 Not imported now - will be brewed somewhere in the Midlands and not the original brew i.e. with a load of crap and chemicals added 💀
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@Thesecretinves2 @saylor Mine’s in my SIPP - so assume good for now Robin?
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STRC & @saylor is paying an 11.5% dividend yield, monthly, and UK investors are starting to ask a serious question.
In the US, some of those distributions are classified as Return of Capital.
Does that classification follow you across the Atlantic?
Here is what I can tell you, and what I cannot.
First, what Return of Capital means in the US.
When a US company distributes ROC, the IRS does not tax it on receipt. Instead it reduces your cost basis in the shares. You pay tax later, on disposal, potentially at capital gains rates.
That is a significant deferral and potentially a lower rate. It is a real advantage for US investors.
The question for UK investors is whether HMRC follows that classification.
The short answer is: not automatically.
HMRC does not simply adopt US tax characterisations. It applies UK rules to determine how a receipt is taxed, regardless of how it is described in another jurisdiction.
Under UK tax law, distributions from a company are generally taxed as dividends.
Foreign dividends from non-UK companies are treated as income and taxed at the dividend tax rates depending on your income band.
That is the default position. The burden is on the taxpayer to argue otherwise.
Could ROC distributions be treated as a part-disposal instead?
Possibly. If a distribution genuinely represents a return of capital rather than a distribution of profits, an argument exists that it should be treated as a capital receipt, reducing your base cost.
But that argument needs to be made carefully and supported. It is not automatic.
The practical picture is messier.
One investor has reported that Hargreaves Lansdown coded their February STRC payment as Return of Capital within their platform.
What a platform codes in its system and what HMRC expects on your tax return are two different things.
HL coding something as ROC does not mean HMRC has confirmed that treatment.
The honest position right now:
There is no published HMRC guidance specifically addressing ROC distributions from US Bitcoin treasury companies received by UK investors.
This is new territory. STRC has only recently become available on UK platforms. The tax treatment is genuinely unsettled.
What this means practically:
If you are receiving STRC distributions and the amounts are material, you need specific advice before filing.
Do not rely on platform coding.
Do not assume the US classification transfers.
Get the position documented.
I am actively looking at this and would genuinely welcome input from anyone who has taken formal advice or had dialogue with HMRC on the point.
If there is a defensible basis for ROC treatment in the UK I want to understand it properly, not assume it.
Summary:
US ROC treatment = real tax advantage for US investors. Confirmed.
UK treatment of the same distributions = unclear.
A capital treatment argument exists but is not settled as yet.
More to follow as this develops.
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@JpakBioMed @jt_stamford Exactly. It’s the level of a rump from a butchers at best.
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@jt_stamford That marbling is nowhere near wagyu class. Not even close.
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@jt_stamford It’s like a standard rump from the butchers. Passable on a decent grill with some bearnaise and a half-decent glass of red, but never wagyu 😅
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Ryan D • retweetledi

Don't want to overstate this but 20-minute highlights of every Premier League game in history, free and on demand, means that this should be a national holiday.
preml.ge/TheArchiveX

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