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PRIVATE CLIENT TAXES
Private client review for April 2023
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).
Private client review for March 2023
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).
Privileged documents and third party notices: how far do HMRC’s information powers reach?
Oliver Marre
Oliver Marre (5 Stone Buildings) examines an FTT decision that provides helpful commentary on the approach to be taken to privileged documents, proportionality and relevance.
Private client review for February 2023
Edward Reed
Toby Ney
When is an interest in possession not an interest in possession? The answer to
this question is one of several new developments reviewed by Edward Reed
and Toby Ney (Macfarlanes).
Private client review for January 2023
Edward Reed
Andy Carruthers
A couple of taxpayer victories concerning the income tax treatment of dividends are among the developments reviewed by Edward Reed and
Andy Carruthers (Macfarlanes).
Private client review for November 2022
Alice Mason
Edward Reed
A couple of further victories for HMRC on SDLT and a couple of victories for the taxpayer regarding information notices are among the developments reviewed by Edward Reed and Alice Mason (Macfarlanes).
No gain, no pain: Sehgal and the remittance basis
Oliver Marre
Oliver Marre (5 Stone Buildings) examines the FTT’s landmark decision that provides the first judicial treatment of some fundamental questions on the remittance basis code.
Private client review for September 2022
Clare Wilson
Edward Reed
Proposed changes to the CGT rules on transfers of property between separating spouses and a tribunal decision on information notices are among the developments reviewed by Edward Reed and Clare Wilson (Macfarlanes).
Private client review for July 2022
Sophie Aitmehdi
Edward Reed
Edward Reed and Sophie Aitmehdi (Macfarlanes) report on several of the most interesting recent tribunal decisions in the private client sphere.
The statutory residence test: an exceptionally useful case on ‘exceptional circumstances’
Catrin Harrison
Dominic Lawrance
Dominic Lawrance & Catrin Harrison (Charles Russell Speechlys) examine the first reported judgment which makes it clear that the relief is there to prevent injustices arising from the prescriptive nature of the statutory residence test.
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208
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
Urgent action could be required on non-dom ‘double remittances’
HMRC set out Pillar Two territories
Additional information requirements for creative industry claims updated
Private schools VAT challenge
HMRC increase late-payment interest rates
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
HMRC v Bolt Services UK Ltd
Other cases that caught our eye: 4 April 2025
HMRC v Innovative Bites Ltd and another
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
Concerns remain over Making Tax Digital
HMRC closing in on tax avoidance (again)
V Louwman v HMRC
B Lynch v HMRC