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Private client review for October 2021

Speed read
The FTT’s decision in Field provides useful insights on discovery, including that a discovery assessment is not invalidated if HMRC changes its mind as to the reasons why there too little tax is borne provided the conclusion is unchanged. Sleigth v Callin is a cautionary tale on potentially insolvent estates. STEP takes a different view to HMRC on the location of cryptoassets for tax purposes. In Priory London, the FTT agreed with HMRC that a valid ATED penalty notice could be given retrospectively, in contrast with Heacham Holidays. An update is expected to HMRC’s trust registration service guidance on mental capacity. HMRC ramps up its use of nudge letters.

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