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This issue of the Rudge Revenue Review examines the Upper Tribunal’s decision in HMRC v. Lee in which the previous decision of the FtT was confirmed in a judgment which…

In this Issue we consider the case of A Taxpayer v. HMRC which is the first case on the provisions of the Statutory Residence Test which was enacted over nine…

Such is the complexity of our tax system that it is unfortunately common for arrangements widely implemented by large numbers of taxpayers not to have the fiscal effects which they…

How does CGT main residence relief apply where a house has been demolished and a new house built?

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.

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 examines the elements of the exceptional circumstances exception and in particular, its application in the COVID-19 pandemic. A case study demonstrates that the exception is of limited practical…

In this issue HMRC’s administrative powers in relation to inheritance tax are considered. The Inland Revenue Charge is discussed in detail.

This issue examines the effects of the proposed transposition of the Fifth Anti-Money Laundering Directive (5MLD) into UK law. It concludes that the proposed legislation will impose administrative burdens far…

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.

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

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

This issue 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…

In this issue the ‘tax gap’ calculated by HMRC is considered and the conclusion is drawn that it is likely that HMRC’s estimate of it is overstated.