Useful insights on discovery, potentially insolvent estates, the location of cryptoassets for tax purposes and HMRC’s use of nudge letters by Edward Reed and Lisa de Silva (Macfarlanes).
More discoveries on discoveries
Albert Szent-Györgyi the Hungarian Nobel prize winner who discovered vitamin C said that ‘discovery consists of seeing what everybody has seen and thinking what nobody has thought’. HMRC and the tribunals continue to give us grounds for commentary on discovery assessments albeit this time under the express powers in respect of SDLT in FA 2003 Sch 10 Part 5 especially para 28.
In GC Field & Sons Ltd and others v HMRC [2021] UKFTT 297 (TC) the First-tier Tribunal (FTT) allowed the taxpayer’s (T’s) appeal and found that discovery assessments issued in respect of SDLT avoidance arrangements were invalid. HMRC had not discharged the burden of proving that either T or their advisers had...
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Useful insights on discovery, potentially insolvent estates, the location of cryptoassets for tax purposes and HMRC’s use of nudge letters by Edward Reed and Lisa de Silva (Macfarlanes).
More discoveries on discoveries
Albert Szent-Györgyi the Hungarian Nobel prize winner who discovered vitamin C said that ‘discovery consists of seeing what everybody has seen and thinking what nobody has thought’. HMRC and the tribunals continue to give us grounds for commentary on discovery assessments albeit this time under the express powers in respect of SDLT in FA 2003 Sch 10 Part 5 especially para 28.
In GC Field & Sons Ltd and others v HMRC [2021] UKFTT 297 (TC) the First-tier Tribunal (FTT) allowed the taxpayer’s (T’s) appeal and found that discovery assessments issued in respect of SDLT avoidance arrangements were invalid. HMRC had not discharged the burden of proving that either T or their advisers had...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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