On 1 August 2008 Jessica is awarded loan notes which will
convert into ordinary shares if she remains in employment for 3
years. She is R/NOR for 2008/09 and R/OR for subsequent years. She
splits her working time between the UK and the USA. She remains in
employment and the loan notes convert on 31 July 2011, giving rise
to a Chapter 3 chargeable event. Jessica claims the remittance
basis under ITA07/S809B for 2008/09.
The relevant period runs from 1 August 2008 to 31 July
2011.
