Revenue Precedents

Will relief under section 514 TCA 1997 be allowed in a company reconstruction where only cash is on offer to employees for their shares? The relief will be applied where: (A) under the terms of the reconstruction shares can be exchanged for cash only, (B) the scheme will be continued by the new company, (C) all the cash is retained by the Trustees and not passed to the participants, and, (D) the total sums are reinvested by the Trustees in shares in the new company, without delay. GM