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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 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.

This issue examines the decisions of the First tier Tax Tribunal and the Upper Tribunal in Bristol & West plc v HMRC and considers HMRC’s subsequent press release.

This issue considers HMRC’s restriction of the relief given by Extra-statutory concession D33 for gains arising on the disposal of certain rights to take Court action.

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.

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.

This issue contains a detailed analysis of the Statutory Residence Test and also considers the unexpected result of the application of FA 2003 s. 75A to an actual client situation.