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Carly Russell

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Farmers and business owners seek Judicial Review of Inheritance Tax Changes to Agricultural/Business Property Relief

Leading Private Wealth law firm Collyer Bristow LLP served proceedings on the Chancellor of the Exchequer and HMRC on 23 June 2025 for a Judicial Review of the government’s decision not to consult on the planned Agricultural Property Relief (APR) …

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2025 Spring Statement

Overall Comment on the Spring Statement The Spring Statement reflects the Government’s continued focus on “closing the tax gap” through increased HMRC powers and enforcement activity.  Many of the measures announced feel like an extension of existing policies rather than …

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Foreign Assets Ruling Suggests New Tax Avoidance Approach

On Nov. 21, the U.K. Supreme Court handed down its decision in Commissioners for His Majesty’s Revenue & Customs v. Fisher on the scope of the U.K.’s transfer of assets abroad, or TOAA, tax code, finding unanimously for the taxpayers …

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Supreme Court rules against HMRC in family business case

The Supreme Court has today (Tuesday 21 November 2023) handed down its decision in the Fisher case on the scope of the UK’s “Transfer of Assets Abroad” (“TOAA”) tax code, finding unanimously for the taxpayers on every point. As Lady …

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Is it illegal for me to pay my handyman in cash?

Is it illegal for me to pay my handyman in cash? Am I breaking the law paying in cash because I am facilitating tax evasion and leaving no paper trail? Would I be liable in any way if he gets …

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COURT OF APPEAL JUDGMENT BRINGS LANDMARK HICBC CHILD BENEFIT CASE TO A SUCCESSFUL CLOSE

The Court of Appeal (Lords Justices Newey, Baker, and Arnold) has today handed down its judgment in HMRC’s appeal in the leading HICBC case (HMRC -v- Wilkes). The Court unanimously rejected every one of HMRC’s arguments, and upheld the Upper …

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HMRC v Wilkes Approved Judgement 07.12.2022

A PDF copy of the Court of Appeal’s judgment.

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Landmark child benefit case reaches Court of Appeal

Wednesday 23 November 2022, London: The Court of Appeal (Lords Justices Newey, Baker, and Arnold) will today hear HMRC’s appeal in the leading HICBC case (HMRC -v- Wilkes). The outcome of this important case again puts the controversial High Income …

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IR35 – Full Circle…for now…

As part of the “mini-budget” set out by then Chancellor Kwasi Kwarteng last month, changes to the IR35 tax rules which were introduced to the public sector in 2017 and to the private sector in 2021 were due to be …

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