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Private client taxes
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PRIVATE CLIENT TAXES
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.
Private client review for June 2022
Andrew Crozier
Edward Reed
Decisions on the validity of discovery assessments and information notices are among the recent developments reviewed by Edward Reed and Andrew Crozier (Macfarlanes).
The impact of war in Ukraine and Russian sanctions: a UK tax adviser’s guide
David Whittaker
David Whittaker (Mishcon de Reya) provides a guide for the UK tax adviser to help them navigate this new complex landscape.
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EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
HMRC manual changes: 22 November 2024
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Autumn Budget 2024: IHT winners and losers
UK signs new double tax treaty with Romania