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PRIVATE CLIENT TAXES
Private client review for March 2023
Hriday Munim
Edward Reed
Two victories for HMRC over claims for SDLT relief and another couple of wins in relation to discovery assessments, are among the developments reviewed by Edward Reed and Hriday Munim (Macfarlanes).
Privileged documents and third party notices: how far do HMRC’s information powers reach?
Oliver Marre
Oliver Marre (5 Stone Buildings) examines an FTT decision that provides helpful commentary on the approach to be taken to privileged documents, proportionality and relevance.
Private client review for February 2023
Edward Reed
Toby Ney
When is an interest in possession not an interest in possession? The answer to
this question is one of several new developments reviewed by Edward Reed
and Toby Ney (Macfarlanes).
Private client review for January 2023
Edward Reed
Andy Carruthers
A couple of taxpayer victories concerning the income tax treatment of dividends are among the developments reviewed by Edward Reed and
Andy Carruthers (Macfarlanes).
Private client review for November 2022
Alice Mason
Edward Reed
A couple of further victories for HMRC on SDLT and a couple of victories for the taxpayer regarding information notices are among the developments reviewed by Edward Reed and Alice Mason (Macfarlanes).
No gain, no pain: Sehgal and the remittance basis
Oliver Marre
Oliver Marre (5 Stone Buildings) examines the FTT’s landmark decision that provides the first judicial treatment of some fundamental questions on the remittance basis code.
Private client review for September 2022
Clare Wilson
Edward Reed
Proposed changes to the CGT rules on transfers of property between separating spouses and a tribunal decision on information notices are among the developments reviewed by Edward Reed and Clare Wilson (Macfarlanes).
Private client review for July 2022
Sophie Aitmehdi
Edward Reed
Edward Reed and Sophie Aitmehdi (Macfarlanes) report on several of the most interesting recent tribunal decisions in the private client sphere.
The statutory residence test: an exceptionally useful case on ‘exceptional circumstances’
Catrin Harrison
Dominic Lawrance
Dominic Lawrance & Catrin Harrison (Charles Russell Speechlys) examine the first reported judgment which makes it clear that the relief is there to prevent injustices arising from the prescriptive nature of the statutory residence test.
Private client review for June 2022
Andrew Crozier
Edward Reed
Decisions on the validity of discovery assessments and information notices are among the recent developments reviewed by Edward Reed and Andrew Crozier (Macfarlanes).
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EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
Tax Journal authors for November 2024
HMRC manual changes: 6 December 2024
Exchequer Secretary committed to MTD timetable following ‘robust’ conversations with HMRC
MTD: catching up with digital records
No new side hustle tax, HMRC confirm
CASES
Read all
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
L v HMRC
Other cases that caught our eye: 6 December 2024
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
IN BRIEF
Read all
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
Read all
The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
Stage One Creative Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others