The private client briefing for November 2012

Another whistleblower has handed data to HMRC, prompting potential enquiries into HSBC Jersey bank account holders. HMRC has extended the deadline for applications to the pilot alternative dispute resolution programme for SMEs and individuals. HMRC has started sending letters in respect of the new child benefit income tax charge which takes effect on 7 January 2013. The government has announced the formation of a GAAR interim advisory group in anticipation of the public consultation on the new guidance to be published in December. A recent Court of Appeal decision could potentially provide employers and their employees an opportunity to claim an NIC refund. A recent Upper Tribunal case upholds the First-tier Tribunal decision in respect of under lease covenants amounting to a gift with reservation of benefit.