Key recent developments in the private client arena are: a stark warning to HMRC that it must keep information confidential (Ingenious Media Holdings); a reminder that convoluted tax planning arrangements are likely to be challenged by HMRC and may well not achieve what was intended (Salinger and J L Kirby); tribunal-endorsed encouragement for taxpayers to propose to HMRC that penalties be suspended in certain circumstances (Duncan); and a landmark Jersey decision in the context of mistake (In the Matter of the D, E and F Trusts).
