Andrew Goldstone and Sarah Albury (Mishcon de Reya) review recent private client tax developments that matter, including the decisions in Miesegaes, Hall, Sparkasse Allgäu and King.
Miesegaes: discovery assessment of life tenant’s return valid despite white space disclosure in trust tax return
In Miesegaes v HMRC [2016] UKFTT 0375 (TC) (reported in Tax Journal 10 June 2016) the First-tier Tribunal has held that a discovery assessment in relation to the tax return of the UK resident life tenant of a Guernsey trust was valid even though HMRC could have found out about the insufficiency of tax declared in the return from the information disclosed in the white space of the trust tax return submitted by the Guernsey trustee. The FTT decided that the existence of the white space disclosure in the trust tax return could not have reasonably been...
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Andrew Goldstone and Sarah Albury (Mishcon de Reya) review recent private client tax developments that matter, including the decisions in Miesegaes, Hall, Sparkasse Allgäu and King.
Miesegaes: discovery assessment of life tenant’s return valid despite white space disclosure in trust tax return
In Miesegaes v HMRC [2016] UKFTT 0375 (TC) (reported in Tax Journal 10 June 2016) the First-tier Tribunal has held that a discovery assessment in relation to the tax return of the UK resident life tenant of a Guernsey trust was valid even though HMRC could have found out about the insufficiency of tax declared in the return from the information disclosed in the white space of the trust tax return submitted by the Guernsey trustee. The FTT decided that the existence of the white space disclosure in the trust tax return could not have reasonably been...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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