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Rudge Revenue Reviews
The Rudge Revenue Review – Issue 25
In this issue HMRC’s administrative powers in relation to inheritance tax are considered. The Inland Revenue Charge is discussed in detail.
Articles
The Sins of the Fathers
This is a short article about HMRC’s administrative powers to recover inheritance tax, highlighting that there is no time limit on HMRC’s powers to issue a notice of determination to…
Articles
A Higher Burden
This article discusses HMRC’s administrative powers in relation to inheritance tax including the Inland Revenue Charge imposed by IHTA 1984 s.237. It highlights the fact that there is no time…
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
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.
Rudge Revenue Reviews
The Rudge Revenue Review – Issue 16
This issue discusses the valuation for Inheritance Tax purposes of an interest in a joint bank account on death and includes an exchange of correspondence with Michael Firth.
Articles
Second Thoughts: An Eagerly Awaited Decision
This article contains a detailed analysis of the Supreme Court’s decision in Futter v HMRC; Pitt & Holt v HMRC and its review of the Hastings-Bass principle.
Rudge Revenue Reviews
The Rudge Revenue Review – Issue 15
This issue examines in detail the Supreme Court’s decision in Futter v HMRC; Pitt & Holt v HMRC and its review of the Hastings-Bass principle.
Articles
Futter & Pitt: the Hastings-Bass Principle
This article considers the review of the Hastings-Bass principle by the Supreme Court in Futter v HMRC; Pitt & Holt v HMRC.
Articles
The Law of Unintended Consequences
In this article the application of the provisions of IHTA 1984 ss. 74A-74C are considered as they apply to excluded property trusts and non-domiciled settlors.
Articles
Unnecessary Complication
This article considers by way of a case study the proposed anti-avoidance legislation now found in IHTA 1984 ss. 74A-74C where interests in settled property in offshore trusts are acquired.
Rudge Revenue Reviews
The Rudge Revenue Review – Issue 12
This issue discusses the proposed anti-avoidance legislation now found in IHTA 1984 ss. 74A-74C and considers whether ‘tax avoidance is ethical’.
Articles
Background to the Extension of the Disclosure Rules to Inheritance Tax – Part II
This article considers the grandfathering provisions found in the Inheritance Tax DOTAS rules and HMRC’s guidance on them.
Lectures
DOTAS and Inheritance Tax
In this lecture the application of the Disclosure of Tax Avoidance Schemes legislation to Inheritance Tax is discussed.
Rudge Revenue Reviews
The Rudge Revenue Review – Issue 10
This issue discusses the use of LLPs as a structure for carrying on ordinary business enterprises and the complexity of asset valuations for Inheritance Tax purposes.
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