Tax planning & anti-avoidance Archives - McKie & Co

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In the case of Tooth HMRC advanced an argument about the meaning of 'deliberately' in the discovery provisions of TMA 1970 s. 29 which was a brazen attempt to subvert…

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.

This issue analyses the professional conduct rules relating to taxation and their effect on members of the CIOT.

This lecture examines the decisions of the First tier Tax Tribunal and the Upper Tribunal in Project Blue Ltd v HMRC. This case involved the construction of the SDLT anti-avoidance…

This lecture examines recent tax cases which are examples of ‘abusive tax collection’ by HMRC and which highlight HMRC’s unconscionable behaviour towards taxpayers.

This lecture concentrates on the anomalies of the Statutory Residence Test.

This article examines the draft anti-abuse rule (the ‘GAAR’) published in a Consultation Document and its implications for tax advisers

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.

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.

This issue discusses the proposed anti-avoidance legislation now found in IHTA 1984 ss. 74A-74C and considers whether ‘tax avoidance is ethical’.

This article examines the application of the proposed general anti-abuse rule to the availability of main residence relief and the incorporation of a business to reduce a tax liability.

This article considers the grandfathering provisions found in the Inheritance Tax DOTAS rules and HMRC’s guidance on them.

A consideration by Simon McKie on whether tax avoidance is wrong.

In this article the proposed GAAR is examined to determine whether its application is to abusive transactions only or to a wider ranging set of transactions.

In this issue the application of the proposed general anti-abuse rule to two difference situations is examined