‘Two film partnerships were carrying on a trade with a view to profit, meaning that loss relief was available to individual investors, the Court of Appeal has decided, restoring a decision of the First-tier Tribunal (FTT).’
OUT-LAW.com, 26th August 2021
Source: www.pinsentmasons.com
‘In this post, Tim Sales, a partner in the Dispute Resolution team at CMS, and Hannah Jones, who works in the Tax team at CMS, comment on the decision handed down by the UK Supreme Court in the matter of Tinkler v Commissioners for Her Majesty’s Revenue and Customs [2021] UKSC 39, which concerned whether estoppel by convention applied to prevent the taxpayer disputing that HMRC had validly served a notice of enquiry.’
UKSC Blog, 25th August 2021
Source: ukscblog.com
‘The tax tribunal has no power to direct that an application by HM Revenue & Customs (HMRC) for a third party information notice be held “inter partes”, that is with the taxpayer or the third party present, the Court of Appeal has confirmed.’
OUT-LAW.com, 10th August 2021
Source: www.pinsentmasons.com
‘This Commons Library paper discusses the way that sales of residential property are taxed, and a series of reforms that have been introduced to stamp duty land tax in recent years.’
House of Commons Library, 10th August 2021
Source: commonslibrary.parliament.uk
‘The UK Supreme Court has upheld the quashing of a “follower notice” that would have required a taxpayer to settle his tax dispute on the basis of a ruling in a different tax case, or to face a large penalty if his dispute was ultimately unsuccessful.’
OUT-LAW.com, 6th August 2021
Source: www.pinsentmasons.com
‘The Supreme Court has unanimously allowed this appeal addressing whether a taxpayer is prevented from challenging the validity of an enquiry into their tax return by HMRC where both parties have proceeded, for nearly a decade, on the mistaken assumption that the enquiry was validly initiated by a letter sent to the taxpayer.’
UKSC Blog, 30th July 2021
Source: ukscblog.com
‘In this post, Tim Sales, a partner in the Dispute Resolution team at CMS, and Hannah Jones, who works in the Tax team at CMS, comment on the decision handed down by the UK Supreme Court in the matter of R (on the application of Haworth) v Commissioners for Her Majesty’s Revenue and Customs [2021] UKSC 25.’
UKSC Blog, 28th July 2021
Source: ukscblog.com
‘Jo Carr-West and Lara Barton, partners at Hunters Law LLP, explain recent recommendations that would assist divorcing couples in minimising and managing the CGT implications of separating their financial affairs.’
Family Law Week, 10th July 2021
Source: www.familylawweek.co.uk
‘Widespread changes to the UK’s IR35 off-payroll working rules came into force on 6 April 2021, and despite a 12-month delay to implementation, detailed HM Revenue and Customs (HMRC) guidance and subsequent amendments to the legislation, areas of uncertainty remain.’
OUT-LAW.com, 21st June 2021
Source: www.pinsentmasons.com
‘The UK Supreme Court has decided that disclosing information in the wrong box on a tax return but explaining it in the white space was not an inaccuracy, as the return had to be considered as a whole.’
OUT-LAW.com, 1st June 2021
Source: www.pinsentmasons.com
‘The Court of Appeal judgment in Finch v Baker [2021] EWCA Civ 72 was released on 28 January 2021. The judgment provides some useful guidance on not being able to get what are essentially conduct arguments contrary to s25(g) through the back door by making “negative contribution” arguments, and it also highlights the importance of ensuring that you adduce and apply for the most appropriate and necessary evidence in advance of a hearing. Simply arguing that an updated pension report is needed, following an appeal hearing, on the basis that the pension sharing order made would not reflect the judge’s intentions as the CE figures would be significantly out of date, is insufficient and misconceived.’
Family Law. 14th May 2021
Source: www.familylaw.co.uk
‘The Supreme Court has unanimously dismissed this appeal concerning issues surrounding the Taxes Management Act 1970.’
UKSC Blog, 14th May 2021
Source: ukscblog.com
‘On 29 April 2021, the government published a consultation on what is to be called the Residential Property Developer Tax (or RPDT). This sets out proposals for the design of a new tax to be charged on the largest residential property developers.’
Practical Law: Construction Blog , 5th May 2021
‘Confidentiality is a fundamental concept at the heart of the modern taxation system. The need to strike a balance between the taxpayer’s right to privacy and the requirement of HMRC to carry out its functions has been the subject of much legislation and litigation.[1] There has been an explosion in the exchange of information between revenue authorities of different countries and British politicians have for years been under pressure to emulate the tradition of American presidents publishing their tax returns. But there is nothing new under the sun: the introduction of income tax in Britain at the end of the 18th century was dominated by concerns over taxpayer confidentiality, which led to measures being developed which have left their mark on today’s income tax system.’
Wilberforce Chambers, 6th April 2021
Source: www.wilberforce.co.uk
‘Mark Watson considers the latest Budget and outlines concerns about the scope for abuse and the response from the Government.’
Carmelite Chambers, 5th March 2021
Source: www.carmelitechambers.co.uk
‘Helen Brander, barrister of Pump Court Chambers, considers the current treatment by the courts and taxation authorities of crypto-assets.’
Family Law week, 3rd March 2021
Source: www.familylawweek.co.uk
‘The Chancellor of the Exchequer delivered his Budget yesterday afternoon. A number of tax measures were introduced to ease the financial burden on businesses and individuals. Some were simply extensions of short-term tax relief, including a holiday on business rates for 3 months, maintaining the £500,000 SDLT nil-rate band, and a freeze on alcohol and fuel duties. In this update, I focus on some longer-term measures designed to promote a post-Covid rebound.’
Wilberforce Chambers, 4th March 2021
Source: www.wilberforce.co.uk
‘R (The Motherhood Plan and Anor) v HM Treasury [2021] EWHC 309 (Admin). In a judgment handed down on 17 February 2021, the High Court has ruled that the Self Employment Income Support Scheme (“the Scheme”) introduced during the coronavirus pandemic does not indirectly discriminate against self-employed women who have taken a period of leave relating to maternity or pregnancy in the last three tax years.’
UK Human Rights Blog, 26th February 2021
Source: ukhumanrightsblog.com
‘Matthew Moore, director of Infolegal, advises family lawyers of their obligations under anti-money laundering regulations following changes [to the] wording of what constitutes taxation advice.’
Family Law Week, 24th November 2020
Source: www.familylawweek.co.uk
‘The Supreme Court has unanimously allowed this long-awaited appeal arising in the course of long-running proceedings known as the Franked Investment Income (“FII”) Group Litigation. The FII Group Litigation brings together many claims concerning the way in which advance corporation tax and corporation tax used to be charged on dividends received by UK-resident companies from non-resident subsidiaries. The respondents to this appeal are claimants within the FII Group Litigation whose cases have been selected to proceed as test claims on certain common issues (“the Test Claimants”). These issues are being determined in phases, with the courts’ decisions affecting not just the other claims within the FII Group Litigation, but potentially also a number of other sets of proceedings brought by corporate taxpayers against the appellant, the Commissioners for Her Majesty’s Revenue and Customs (“HMRC”).’
UKSC Blog, 20th November 2020
Source: ukscblog.com
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