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Cases cited in support of reasonable excuse appeal were created by AI.
When is an interest in possession not an interest in possession? The answer to this question is one of several new developments reviewed by Edward Reed and Toby Ney (Macfarlanes).
Helen Adams (BDO) considers the extent to which taxpayers may have a reasonable excuse if they are affected by the coronavirus pandemic and the UK’s lockdown.

HMRC’s ‘mantra’ for the definition of reasonable excuse

The First-tier Tribunal has not taken a consistent approach in deciding whether or not there is a reasonable excuse for non-resident capital gains tax (NRCGT) being filed late.

Helen Adams and Youcef Toumi (BDO) examine the current state of the legislation and case law on reasonable excuse, including how the concept may alter in future.

Some tribunals appear more sympathetic than others.

When is an application to reduce penalties because of ‘special circumstances’ a better bet than ‘reasonable excuse’? Peter Vaines (Squire Patton Boggs) considers a recent tribunal decision.

Andrew Goldstone and Victoria Howarth provide an update, including: the increased transparency of ownership of UK companies; new HMRC guidance on the taxation of damages; a recent decision on reasonable excuse for late returns; and why professionals acting as charity trustees need to be aware of potential conflicts of interest

Simon McKie says J Woolf was the ‘result of another morally shocking decision to litigate by HMRC’.