Private client review for April 2019

The government has launched a consultation on CGT principal residence relief. In Farrow v HMRC, the FTT set aside a personal liability notice issued to a company’s directors in respect of the company’s reporting failures. The latest edition of PCRT places greater emphasis on a tax adviser’s role in tax planning arrangements. In Villar v HMRC, the sale proceeds of an orthopaedic consultant’s practice were held to be capital rather than income. The gift aid donor benefits rules have been simplified from 6 April 2019. In Beadle v HMRC, the taxpayers failed in their indirect challenge to the validity of PPNs and APNs. A Treasury report robustly defends the new 12 year time limit for offshore discovery assessments. In Khan v HMRC, the FTT provided a useful overview of case law on trading versus investment.