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SUPREME-COURT


Card image Julius Konstantin Berling Liesl Fichardt Emily Au
Who proves what? Liesl Fichardt, Emily Au and Julius Konstantin Berling (Quinn Emanuel) set out how penalty appeals now divide the burden between HMRC and the taxpayer – and why the line between the two is far from settled.
Stage three of the RMC test is where the real action now lies, writes Henry Bennett-Gough (Simmons & Simmons).
Paul Farey (AECOM) assesses how the Supreme Court’s stricter approach narrows the scope for capital allowances on preparatory expenditure.
Once again, the US dominates the international tax news cycle, reports Tim Sarson (KPMG).
Discretionary deferred profits via a corporate LLP were taxable as miscellaneous income

Nick Wright (Jerroms Miller) considers how the new close company reporting regime changes the risk profile for alphabet shares, dividend planning and employee share arrangements in owner-managed businesses.

Individual match contracts were not contracts of employment
The Supreme Court stands at the head of the UK’s judicial appeals system. Malcolm Gammie CBE KC (One Essex Court) examines when permission to appeal to the Supreme Court is likely to be granted, and considers how taxpayers and HMRC are faring in securing permission.
Anthony Inglese CB talks to David Milne KC about life at the Tax Bar and beyond.
Laura Poots (Pump Court Tax Chambers) shares some tips for minimising last minute procedural issues and also reports some positive developments in diversity at the Bar.
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