Blog Archives

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 …

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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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Collyer Bristow Annotations on the discovery assessments policy paper

Policy paper Discovery assessments Published 27 October 2021 Who is likely to be affected Individuals who incur certain tax charges (the High Income Child Benefit Charge (HICBC), those relating to Gift Aid Donations and a number of different pension charges) …

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High income child benefit charge: An update

Many of you have been in touch following our Upper Tribunal success in HMRC v Wilkes regarding HICBC disputes- we thank you for your interest in this case and its consequences for affected tax payers. You can read the original …

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HICBC ruling in the Upper Tribunal: an update

We are delighted to announce our Upper Tribunal success in HMRC v Wilkes regarding HICBC disputes. More details can be found via our press release. HMRC has until the end of July to decide whether or not to seek a …

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HUNDREDS OF THOUSANDS OF TAXPAYERS TO BENEFIT AS HMRC LOSES LANDMARK CASE CHALLENGING HIGH INCOME CHILD BENEFIT CHARGE

Summary: HMRC has lost its Upper Tribunal appeal – on every point – in Jason Wilkes’s leading case on the controversial High Income Child Benefit Charge (the HICBC) The outcome should benefit hundreds of thousands of taxpayers whose assessments to …

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Collyer Bristow instructed in HMRC -v- Wilkes : High Income Child Benefit Charge

On Wednesday 26 May 2021, the Upper Tribunal (The Hon. Mrs Justice Falk DBE and Judge Timothy Herrington) will hear HMRC’s appeal in the leading “High Income Child Benefit Charge” (the HICBC) case. The taxpayer assessed to the HICBC is …

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‘Tax Day’ – government continues its campaign to tackle non-compliance

Promoters of tax avoidance schemes HM Treasury’s reminder that the so-called “tax gap” is at a record low of 4.7% (of which tax avoidance only counts for £1.7bn – approximately 5.5% of the total) is timely and welcome.  HMRC has …

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Corporate residence of subsidiaries: Court of Appeal decision provides more questions than answers

Though the CA judges unanimously agreed that the UT’s reasons for overturning the FTT decision were flawed, the judges disagreed on whether the FTT decision might have been wrong for other reasons – an issue that was strictly out of …

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