DOMICILE

HICBC and discovery assessment powers: There is no sign of the flow of high income child benefit charge (HICBC) cases drying up. HMRC presumably hoped that the retrospective legislation to reverse the decision in Wilkes [2020] UKUT 150 (TCC), where...

Dominic Lawrance

Catrin Harrison

Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) examine the Court of Appeal’s decision on partial closure notices in respect of domicile cases.

Lynnette Bober

Lynnette Bober (Gateley Legal) focuses on some key issues and problem areas which are likely to cross many advisers’ desks this year.

Damiano Sogaro

Gideon Sanitt

Damiano Sogaro and Gideon Sanitt (Macfarlanes) review recent litigation on the tribunal's role in determining domicile issues when considering challenges to an enquiry or to information notices.

Dominic Lawrance Hugh Gunson Catrin Harrison

Catrin Harrison, Dominic Lawrance and Hugh Gunson (Charles Russell Speechlys) examine an Upper Tribunal decision that is disappointing for taxpayers and removes a strategic weapon for anyone faced with a domicile enquiry.

Emma Chamberlain

Emma Chamberlain OBE (Pump Court Tax Chambers) examines some important amendments to the excluded property provisions governing settlements.

Nick Clayton

Dawen Gao

In Henkes, the tribunal decided it can decide a taxpayer’s domicile status when determining an application for the closure of a domicile enquiry, as Nick Clayton and Dawen Gao (Herbert Smith Freehills) explain.

James Austen

The tribunal decides it has jurisdiction to determine domicile in closure notice applications.

Michelle Sloane

Adam Craggs

In this quarterly review, Adam Craggs and Michelle Sloane (RPC) consider HMRC’s increasing propensity to seek the production of documents from accountants and other professional advisers, HMRC’s new policy of challenging taxpayers’ loan relationships, and the increase in the number of domicile enquiries launched by HMRC.

Claire Weeks

Emma-Jane Weider

Emma-Jane Weider and Claire Weeks (Maurice Turnor Gardner) focus on those UK resident individuals who are non-UK domiciled but who will become ‘deemed domiciled’ for tax purposes from the start of the 2019/20.

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