PRIVATE CLIENT TAXES

Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) give a festive appraisal of the key case decisions in 2023 affecting private clients.

Helin Gurel

Edward Reed

CGT successes, a question of values and when two become one... Edward Reed and Helin Gurel (Macfarlanes) provide this month’s private client update.

Edward Reed

Thomas Schlee

The BlueCrest salaried members case, three HMRC victories on SDLT and three recent taxpayer wins on penalties. Edward Reed and Thomas Schlee (Macfarlanes) review recent developments in the private client world.

Liesl Fichardt

Emily Au

In recent years, LLPs have been the focus of ongoing challenges by HMRC – this is to become even more complex as HMRC seek to challenge the nature of a ‘capital’ stake in an LLP. Liesl Fichardt and Emily Au (Quinn Emanuel) examine the key issues.

David Whiscombe

David Whiscombe asks whether it is fair for a taxpayer to be effectively taxed twice on the basis of a mutually exclusive analysis of the same transaction.

Nisha Majumdar

Edward Reed

Edward Reed and Nisha Majumdar (Macfarlanes) review recent cases on reasonable excuse, HMRC fishing expeditions and the SDLT mixed-use rate.

Andrew Crozier

Edward Reed

Recent cases on information notices, penalties, and what is and is not a ‘mistake’ are reviewed by Edward Reed and Andrew Crozier (Macfarlanes).

Edward Reed

Tristan Honeyborne

The burden of proof as regards the taxpayer behaviour, late appeals and cautionary tales for IHT planning are among the topics featuring in this month’s review by Edward Reed and Tristan Honeyborne (Macfarlanes).

Hannah Kalveks

Edward Reed

SDLT mixed use rates, procedural issues, taxpayer confidentiality and HMRC ‘fishing expeditions’ are among the topics reviewed by Edward Reed and Hannah Kalveks (Macfarlanes).

Hriday Munim

Edward Reed

Two victories for HMRC over claims for SDLT relief and another couple of wins in relation to discovery assessments, are among the developments reviewed by Edward Reed and Hriday Munim (Macfarlanes).

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