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When does the period of ownership for private residence relief begin? This question was considered by the Upper Tribunal in HMRC v Lee

The CGT consequences of typical transactions in respect of flat management companies can produce an unwelcome surprise

It must, surely, not be uncommon for buyers of residential properties substantially to reconstruct them or to demolish the existing building and to build a replacement residence. Yet the application…

In three recent cases on the CGT treatment of lost deposits, Hardy, Lloyd-Webber and Drake, HMRC, in order to maximise its revenue, attempted to exploit, successfully in two of the…

This article examines the elements of the exceptional circumstances 60 day exception and in particular, its application in the COVID-19 pandemic. A case study highlights the deficiencies of the exception.

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.

This article illustrates the application of the different elements of the statutory residence test by reference to the circumstances of Prince Harry. It includes a discussion of the split year…

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…

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…

This article examines the effects of the proposed transposition of the Fifth Anti Money Laundering Directive (5MLD) into UK law and the administrative burdens that it will place on a…

This article examines the importance for a taxpayer of making a detailed disclosure with his tax return to HMRC as to his residence and domicile in view of the increasing…

An article based on an actual case on which we advised involving a typical offshore trust and company structure into which HMRC raised an enquiry alleging a deliberate omission by…

This article examines the practical importance of the definitions of Scottish and Welsh taxpayers and their interaction with each other and with the Statutory Residence Test.

This article considers the intra-UK residence rules and the interaction of the definitions of Scottish and Welsh taxpayers.

This is the second of two articles which examines the decision of the Upper Tribunal in Project Blue Ltd v HMRC. It considers the argument presented by the taxpayer that…

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