2021

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Unconvincing promotions
Many years after most responsible advisers abandoned recommending tax avoidance schemes to their clients because they were no…
Residence of convenience
Even experienced tax advisers often assume that the summaries of fiscal law in HMRC’s Manuals have been arrived…
Parallel Worlds
Cases often reveal the Judiciary’s assumptions about the society in which we live. Those assumptions are often startlingly…
Artificial Tax Planning
Tax planning normally involves planning not to pay tax, or at least to reduce the amount of tax…
Valuable Expertise?
Valuation, it is often said, is not an art but a science.  A recent case suggests that it…
Power without Responsibility
Those who deal regularly with matters of domicile and residence know that HMRC routinely requests large shopping lists…
Time’s Fools
We have always enjoyed explaining to our clients why the UK’s fiscal year ends on 5th April.  A…
A Happy 21st for the Tax Cartel
Imagine that the major food manufacturers combined to place a minimum price on food so as to restrict…
First Tier Union
It is for the Court to determine what is the content of the law of the country in…
Rediscovery
Sean Kelly v. HMRC [2021] is an interesting case in which assessments were issued in 2016 on the…
A Sad Case
The case of D Austin v. G Mitchell and another [2020] is an interesting, unusual and affecting non-tax…
Partners in Crime
The case of XL Insurance Company SE and IPORS Underwriting Limited, Paul Alan Corcoran v. HMRC and others…
Your money or your life
HMRC’s overwhelming resources often allows it to collect tax which is not due.  A taxpayer assessed on a…
Paradise regained
As we adapt to the restoration of our sovereignty, the opportunities and minor irritations resulting from Brexit continue…
Low standards
Many years after tax avoidance ceased to be effective in the UK, a few fly-by-night operatives continue to…
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