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Unknown Unknowns

Murray Clayson and Susie Brain of Freshfields Bruckhaus Deringer LLP comment on the recent issue of 'generic' information demands to financial institutions
'There are known knowns. These are things we know that we know. There are known unknowns. That is to say there are things that we now know we don't know. But there are also unknown unknowns. These are things we do not know we don't know.' (US Defense Secretary Donald Rumsfeld 12 February 2002.)
On 12 August 2009 the First-tier Tribunal decided in favour of HMRC upon the latter's application for approval of 308 notices seeking details of non-UK accounts held by persons with UK addresses to be served on financial institutions under FA 2008 Sch 36 para 5. The Tribunal hearing...

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