The Rudge Revenue Review – Issue 33

Home Publications Rudge Revenue Reviews The Rudge Revenue Review – Issue 33
1st November 2023

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 includes a comprehensive consideration, and rejection, of HMRC’s arguments in the matter. The case, which has caused something of a stir in the Daily Telegraph, concerned determining the ‘period of ownership’ for the purposes of Main Residence Relief from CGT and is a good example of the application of the fundamental principles of statutory construction to complex fiscal provisions.

In writing this issue of the Review, we have been fortunate to have as our co-author, Sam Dewes, a director in the private client department of HW Fisher, a noted expert on the taxation of UK and international private clients, an accomplished writer on taxation matters and a fellow member, with us, of the Private Client Committees of the CIOT.