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Blog Archives
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 …
Posted in Longer Reads
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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 …
Posted in Longer Reads
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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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Tagged HICBC, HMRC, Wilkes
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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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HICBC: January 2022 update – 2017/2018 tax position
Self-Assessment In their letters, HMRC correctly notes that the Upper Tribunal mentioned the fact that, if HMRC act within the statutory 4-year tax filing deadline, they can require HICBC taxpayers to file a self-assessment tax return. This means that the …
Posted in Shorter Reads
Tagged HICBC, High Income Child Benefit Charges, HMRC, tax
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US tax changes could be imminent
The US House Committee on Ways and Means has proposed a raft of US tax changes intended to help fund the new administration’s grand infrastructure programme. Contained within the proposals are significant changes to some key estate planning tools that …
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Retrospective changes proposed to HMRC HICBC Discovery Assessment Powers
In the 2021 Budget, the Government published a little-noticed policy paper on Discovery Assessments in parallel with the Budget and Spending Review documents. See the paper here. The lack of attention was probably caused by the fact that the paper …
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Tagged discovery assessments, HICBC, High income child benefit, HMRC appeal, tax disputes, taxpayers
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