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APPEALS209CA89E-4112-4CDC-B8DB-D791CE3CF498
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
Craig Kirkham-Wilson
Lauren Trask
Form over influence? Constantine Christofi, Craig Kirkham-Wilson and Lauren Trask (EY) examine the Supreme Court’s decision in BlueCrest and what it means for Conditions A and B of the salaried members rules.
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
Ollie Winters
Jade Du Berry
The High Court has confirmed that HMRC do not have a veto over
restructuring plans. Alan Rafferty, Jade Du Berry and Ollie Winters (Milbank)
examine the implications of Waldorf, including HMRC’s constitutional
arguments, the treatment of tax losses and the evolving approach to cross-class
cram downs.
Strike-out!
Glyn Edwards
Glyn Edwards (MHA) examines an apparent increase in HMRC strike-out applications and why many are failing to clear the tribunal’s high threshold.
P Reed v HMRC
Unauthorised payments charge and surcharge: discovery assessment
St Patrick’s International College Ltd and others v HMRC
CA allows taxpayer’s appeal on VAT exemption and private higher education providers
Other cases that caught our eye: 10 July 2026
SKAT fraud claim survives issue estoppel challenge: Readers may recall SKAT’s attempt to pursue a fresh fraud claim in England against MCML, formerly ED&F Man Capital Markets Ltd, over allegedly false tax vouchers used to obtain Danish...
Other cases that caught our eye: 3 July 2026
Follower notices and corrective action: C Maguire v HMRC [2026] UKFTT 929 (TC) (18 June) is a rare example of a taxpayer succeeding in an appeal against a penalty for failing to take corrective action after receiving a follower notice. The taxpayer...
Lifeplus Europe Ltd v HMRC
FTT allows appeal against transfer pricing information notice seeking US parent company accounts
H Gwyn-Jones v HMRC
HMRC granted permission to amend their statement of case
J Herrmann v HMRC
No late payment penalties on reallocation of earlier tax payments
Go to page
of
3
EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
Read all
Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
Read all
Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
MOST READ
Read all
The VAT treatment of prize draws
The new duty to correct tax return errors
Loan charge settlement scheme: regulations and guidance published
Requirements for forthcoming pensions IHT changes
One minute with... Tim Gummer