Film Partnerships: Eclipsing the Litigation and Settlement Strategy
The new settlement opportunity for members of Eclipse Film LLP was reported in Taxation, 16 September 2021. The first part of this...
03.04.2022Insights
Disguised Remuneration. A fragile state: Part 2
Both tax planners and HMRC often approach case law with a similar aim albeit from a different direction. The object is to extrapolate...
03.04.2022
Disguised Remuneration. A fragile state: Part 1
2021 has been an interesting year for disguised remuneration schemes (DRs). Following the Supreme Court’s decision in what is usually known as the Rangers case...
03.04.2022
Bridge Over Troubled Waters? The confluence of trust and tax law (re EFG Trust Co Ltd)
The Royal Court of Jersey was approached by the settlor of a Jersey discretionary trust to set aside certain transfers into the Trust through a bank...
03.04.2022
HMRC Evaluation of Powers and Safeguards
Since the 2008 financial crash, there has been a steady flow of articles in Taxation commenting on new legislation designed to assist tax compliance....
08.10.2020
Coronavirus and tax policy
Covid-19 has encouraged predictions on how it will change our world. Bearing in mind Darwin’s observation that ignorance more frequently begets...
28.07.2020
The Tax Tribunal – limiting the costs of an appeal
The following comments assume some familiarity with the role of the Tax Tribunals (First Tier Tribunal and Upper Tribunal)...
14.06.2020
UK tax position for individuals who are UK tax resident but not domiciled in the UK (RNDs)
The tax position of individuals who are UK tax resident non-domiciliaries (RNDs) is complex. The default tax position for individuals who are UK tax resident is...
03.05.2020
Offshore tax and “failure to correct” legislation: the requirement for perfection
2017 saw the introduction of new penalties for non-compliance in matters involving offshore tax.
29.04.2020
Catching up from late 2019: offshore avoidance legislation; culpability
Many advisers have expressed concern at the HMRC tendency to view any arrangement which reduces a tax bill as "avoidance" and, if a challenge is successful...
05.11.2019
The loan charge and disguised remuneration: an uncertain future
There has been substantial press coverage on the introduction of the loan charge and a recent government promise of review...
30.09.2019
The John Doe Summons: the USA and tax transparency
The USA is criticised for many things. In the world of tax, over 100 countries have signed up to the CRS regime designed to exchange information with a...
28.08.2019