Appeals & other tax litigation

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Of Interest?
The case of the Raboni Estate v. HMRC casts a little more light on the nature of an…
‘Fings ain’t what they used to be’
Cases in respect of the law of residence before the SRT came into force continue to come before…
Unappealing odds
The risks of tax litigation are stacked against the taxpayer. The rewards of success in fiscal litigation must…
Constructive confinement
The decision in Embiricos takes a puzzlingly restricted view of the scope of partial closure notices.
Unconvincing promotions
Many years after most responsible advisers abandoned recommending tax avoidance schemes to their clients because they were no…
Valuable Expertise?
Valuation, it is often said, is not an art but a science.  A recent case suggests that it…
Power without Responsibility
Those who deal regularly with matters of domicile and residence know that HMRC routinely requests large shopping lists…
First Tier Union
It is for the Court to determine what is the content of the law of the country in…
Rediscovery
Sean Kelly v. HMRC [2021] is an interesting case in which assessments were issued in 2016 on the…
Partners in Crime
The case of XL Insurance Company SE and IPORS Underwriting Limited, Paul Alan Corcoran v. HMRC and others…
Your money or your life
HMRC’s overwhelming resources often allows it to collect tax which is not due.  A taxpayer assessed on a…
A Gordon Tonic
Fastklean Ltd v. HMRC & K Gordon is an interesting procedural case. The FTT had heard an appeal…