COTTER

Michael Avient reviews the decisions in Cotter, Rouse and De Silva and provides considerations for advisers when advising on loss carry-back claims.

By BKL Tax, BrassTax News

A look back on some of this year’s key developments:

• Mike Lane takes stock on the BEPS project, and what to expect;
• David Quentin gives an outspoken view on how business and tax professionals responded to the tax avoidance debate in 2013;
• Adam Craggs sums up some cautionary tales for advisers in the light of the BAA, Mehjoo and Cotter decisions this year.

Michael Avient answers a query on the payment of tax on trading losses that are the subject of an enquiry.

Wendy Walton and Miranda Chamberlain review recent changes affecting private client advisers, including the Cotter decision, a case on legal professional privilege, the UK share registry plan, an update on claims against foreign estates, and the retrospective application of the Hastings-Bass principle in Jersey.

David Whiscombe considers the recent decision of the Supreme Court in Cotter.

The Supreme Court has found in favour of HMRC in the Cotter case, overturning the previous decision of the Court of Appeal.