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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
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
Unsettled Trust
In this article an anomaly in respect of settlements creating interests in possession for a settlor and, or, his spouse when the property vests is examined taking into account IHTA…
Rudge Revenue Reviews
The Rudge Revenue Review – Issue 7
This issue contains a ‘mixed bag’ of items including articles on HMRC’s warning on phishing emails, HMRCs’ consultation process, the Government’s u-turn on increasing cider duty and the use of…
Articles
A Settled Purpose – Inheritance Tax Planning Through Trusts
This article examines the use of settlements to make effective gifts of assets whilst retaining control of those assets.
Articles
Tax Trap: The Sections 80 and 82 Anomaly
This article identifies a tax trap for trusts with an initial interest in possession for the settlor.
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