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Private client briefing for June 2018

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The OTS published a report on savings and investment income. In Harris v HMRC the FTT held a personal representative liable for the payment of inheritance tax even though he had distributed the estate to the beneficiary on the understanding that the beneficiary would pay the tax due. HMRC agreed that offshore trusts holding UK residential property via an offshore close company do not need to register with the trust registration service in the year that an inheritance tax liability arises. In R (Haworth) v HMRC the High Court upheld yet another taxpayer's judicial review application against the issue of follower and accelerated payment notices. HMRC revised its non-statutory clearances guidance. In Hart v HMRC the taxpayer's ignorance of the requirement to submit a non-resident CGT return was not a reasonable excuse but his reliance on his adviser was. HMRC has introduced two restrictions to non-statutory...

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