Tori Magill (Pinsent Masons) answers a query on the validity of a discovery assessment received by a taxpayer who participated in a marketed tax avoidance scheme.
Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City, including the latest proposals on tackling tax evasion and avoidance; the EU’s tax transparency measures; and recent cases illustrating the limits of the purposive approach.
Gideon Sanitt (Macfarlanes) considers the decision in Ingenious Media and when HMRC may be excused from its duty of confidentiality.
David Pickstone (Stewarts Law) reviews the recent Upper Tribunal decision in Ingenious, which considered whether HMRC could make allegations of dishonesty at a late stage in proceedings without having pleaded them in its statement of case.
The Treasury has published its proposed next steps on tackling evasion and avoidance. James Bullock (Pinsent Masons) reviews the detail.
Criticism of HMRC’s failure to prosecute HSBC Swiss tax evaders has been quite unfair, writes Jonathan Fisher QC (Devereux Chambers). There are problems with criminal prosecution and the decision to focus on tax collection through civil settlement is the right one. It makes little sense to criminally prosecute these cases.
The substantial shareholdings exemption is in danger of being misunderstood, warns Heather Self (Pinsent Masons)
Dawn Register and Helen Adams (BDO) take a look at the consultation proposals to strengthen sanctions for tax avoidance
Jolyon Maugham (Devereux Chambers) writes that morality has its uses. As a tool for delivering tax outcomes it is highly imperfect, but the law falls into disrepair when it does not keep pace with changing mores.
Recent media reports about the London mayor’s tax affairs shine a light on the taxation of US citizens living abroad. David Treitel (American Tax Returns Ltd) explains.