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Residence of convenience
Even experienced tax advisers often assume that the summaries of fiscal law in HMRC’s Manuals have been arrived…
11 October 2021
Parallel Worlds
Cases often reveal the Judiciary’s assumptions about the society in which we live. Those assumptions are often startlingly…
1 October 2021
Artificial Tax Planning
Tax planning normally involves planning not to pay tax, or at least to reduce the amount of tax…
25 September 2021
Valuable Expertise?
Valuation, it is often said, is not an art but a science.  A recent case suggests that it…
2 August 2021
Power without Responsibility
Those who deal regularly with matters of domicile and residence know that HMRC routinely requests large shopping lists…
24 July 2021
Time’s Fools
We have always enjoyed explaining to our clients why the UK’s fiscal year ends on 5th April.  A…
30 June 2021
First Tier Union
It is for the Court to determine what is the content of the law of the country in…
1 June 2021
A Sad Case
The case of D Austin v. G Mitchell and another [2020] is an interesting, unusual and affecting non-tax…
31 May 2021
Partners in Crime
The case of XL Insurance Company SE and IPORS Underwriting Limited, Paul Alan Corcoran v. HMRC and others…
1 April 2021
Your money or your life
HMRC’s overwhelming resources often allows it to collect tax which is not due.  A taxpayer assessed on a…
14 March 2021
Paradise regained
As we adapt to the restoration of our sovereignty, the opportunities and minor irritations resulting from Brexit continue…
14 March 2021
Low standards
Many years after tax avoidance ceased to be effective in the UK, a few fly-by-night operatives continue to…
14 March 2021
Involuntary Audience
The case of N v. HMRC (CHB) [2021] was an interesting non-tax case of relevance to tax practitioners. …
28 February 2021
‘From ignorance our comfort flows …’
In estate planning, family members often have to act together.  In order for them to do so, however,…
14 February 2021
A Gordon Tonic
Fastklean Ltd v. HMRC & K Gordon is an interesting procedural case. The FTT had heard an appeal…
10 January 2021
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