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The private client review for January 2020

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In Routier and another, the Supreme Court rejected HMRC’s argument that a charity set up to build homes for the elderly in Jersey did not qualify for the IHT charity exemption. In Estate of Thomas (deceased), the Upper Tribunal allowed an appeal by personal representatives, assessing that, where land that attracts an inheritance tax charge is sold ‘off market’, the sale price should be the best price that could reasonably have been obtained for the land at the time of the sale. In Rogers and another, it was held that a notice under TMA 1970 s 8 to file a return does not have to be issued by a ‘flesh and blood’ officer of HMRC. HMRC has published its view that the situs of cryptoassets depends on the residence status of the beneficial owner.

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