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Rudge Revenue Reviews
The Rudge Revenue Review – Issue 29
The cases of Hardy, Lloyd-Webber and Drake reveal the asymmetric CGT effects of forfeited deposits and a more fundamental and long-stranding defect in the CGT legislation.
Rudge Revenue Reviews
The Rudge Revenue Review – Issue 27
The case of Boston Khan v. HMRC [2021] calls into question the Courts’ even-handedness in applying basic principles of statutory construction where their effect is beneficial to the taxpayer.
Articles
A Lull Before the Storm
This short article considers the 30-day reporting requirement for all direct disposals of UK land from the perspective of both the taxpayer himself and of the solicitor acting for him.
Rudge Revenue Reviews
The Rudge Revenue Review – Issue 23
This issue discusses the importance to a taxpayer of making a detailed disclosure with his tax return to HMRC as to his residence and domicile status.
Lectures
Deemed Domicile – The Proposed Changes
The main subject of this conference is domicile including the recently domiciled, long-term resident and formerly domiciled rules.
Lectures
Overstepping the Line
This lecture examines recent tax cases which are examples of ‘abusive tax collection’ by HMRC and which highlight HMRC’s unconscionable behaviour towards taxpayers.
Articles
Doing Good by Stealth?
This short article discusses HMRC’s change in its guidance following the CIOT’s representations based on the example in Simon McKie’s article Fair Administration?
Articles
Fair Administration?
This article considers HMRC’s restriction of relief given by Extra-statutory concession D33 for gains arising on the disposal of certain rights to take Court action
Rudge Revenue Reviews
The Rudge Revenue Review – Issue 17
This issue considers HMRC’s restriction of the relief given by Extra-statutory concession D33 for gains arising on the disposal of certain rights to take Court action.
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