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David Pett (Temple Tax Chambers) discusses the trustee’s duties to consider what is in the best interests of the beneficiaries as a class, how the sale proceeds are to be distributed and the tax consequences of any sale.
FTT rejects transitional provision carried interest appeals.
Bonus arrangements were fully taxable: Lynx Forecourt Ltd v HMRC [2024] UKFTT 278 (TC) (27 March 2024) is an appeal that relates to bonus arrangements put in place as far back as 2003. They were designed to exploit the rules which existed at the...
Preparatory steps insufficient to crystalise disposal for CGT purposes 
Follower notices and penalties: R Baker v HMRC [2024] UKFTT 126 (TC) (6 February 2024) is the second case in which the tribunal has allowed appeals against penalties under the follower notice regime arising from the taxpayer participating in a scheme...
Cases cited in support of reasonable excuse appeal were created by AI.
Upper Tribunal sends PPR appeals back to the FTT.
Share exchange scheme was not the main purpose to avoid CGT
Pete Miller and Nick Wright (Jerroms Miller) answer some of the key questions on this valuable regime.
SDLT mixed use rates, procedural issues, taxpayer confidentiality and HMRC ‘fishing expeditions’ are among the topics reviewed by Edward Reed and Hannah Kalveks (Macfarlanes).