Acting in a domicile dispute for a wealthy businessman who has lived in the UK since arriving as a refugee in WW2.  This included a Judicial Review (in the High Court and Court of Appeal) of HMRC’s decision to resile on its prior decision to treat him as “non-dom”.  Also acting in an appeal against a Schedule 36 Information Notice raising similar public law grounds in the FTT.  Additionally, advising on and implementing UK and worldwide tax/succession/estate planning for him, his valuable trading business, and his offshore trust.

Acting in an FTT appeal against out-of-time Discovery Assessments issued for supposedly “careless” behaviour relating to the SDLT implications of a complex property purchase, where the appellants had taken great care to obtain SDLT advice from a reputable accountant.

Acting in the FTT appeal against Discovery Assessments issued by HMRC in respect of the transitional provisions in the 2015 changes to the Private Equity “carried interest” tax regime.

Successfully acted (pro-bono) in the Upper Tribunal and Court of Appeal in the high-profile leading appeal against HMRC’s ability to levy Discovery Assessments to recover the “High-Income Child Benefit Charge”; the government changed the law with retrospective effect to reverse those decisions.  Now acting (pro-bono) in two forthcoming conjoined appeals in the Upper Tribunal against those retrospective measures.

In private correspondence with HMRC during their enquiry into our client’s tax return, persuaded HMRC to change their view on whether a gift by a UK-resident non-dom to a foreign charity should be subject to UK tax – without the need to appeal to the FTT.  Applying the Supreme Court’s decision in the groundbreaking Routier case to the “new” tax definition of “charity” in Finance Act 2010, we succeeded in satisfying HMRC that UK law was not compliant with EU law (which was then in force) and that tax ought not to be payable.

Advised on and carried out disclosures for numerous clients under HMRC’s “Worldwide Disclosure Facility” to regularise offshore tax non-compliance and the “Digital Disclosure Service” in respect of onshore non-compliance.

Advised an elderly and vulnerable lady about her many UK farming and business ventures (including a complex 50/50 joint venture with another family) and the tax and succession issues arising.  After her death, acting in the Probate of her estate, including the associated IHT issues.

Advised numerous clients about UK law on “central management and control”, whereby foreign companies can become treated as tax-resident in the UK, including the related HMRC guidance.  This was particularly relevant when the shareholder/director clients were themselves becoming resident in the UK.  Advised the clients that, with suitable care and planning, they could ensure that their companies would not become subject to UK tax.

Advising non-dom clients on a tax-efficient trading structure to prepare for market and then sell on the international market regulated products currently in the UK.  This took into account transfer-pricing issues, Corporation Tax, VAT, and personal/trust tax issues for the UBOs.

Advised several clients about HMRC’s change of approach following the Supreme Court’s decision in the Anson case, which decided that UK resident taxpayers having interests in US LLCs ought not to be subject to double taxation.  Settled “white space” wording for those clients making claims for Anson treaty relief in their tax returns.