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Private client review for July 2019

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Recent figures show significantly increased HMRC tax recovery from offshore account holders. The decision in Hartogs provides useful guidance on when the court may rescind a transfer where there was an operative mistake as to the tax consequences. The definition of ‘tax adviser’ for purpose of the money laundering rules was considered by the Upper Tribunal in Online Tax Rebate Ltd. In Archer, the Court of Appeal ruled that where a taxpayer wants to challenge the issue of an APN, taxpayers should first exhaust the representations procedure before making a judicial review claim. The Office of Tax Simplification has published its recommended reforms to inheritance tax.

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