Recent decisions on mixed use SDLT, taxpayer behaviour and the meaning of ‘service’ under the remittance basis rules are reviewed by Edward Reed and Sam Epstein (Macfarlanes).
Edward Reed and Emma Critchley (Macfarlanes) recap the key private clients announcements in the Spring Budget, and they report some interesting procedural points when challenging HMRC enquiries.
The BlueCrest salaried members case, three HMRC victories on SDLT and three recent taxpayer wins on penalties. Edward Reed and Thomas Schlee (Macfarlanes) review recent developments in the private client world.
In recent years, LLPs have been the focus of ongoing challenges by HMRC – this is to become even more complex as HMRC seek to challenge the nature of a ‘capital’ stake in an LLP. Liesl Fichardt and Emily Au (Quinn Emanuel) examine the key issues.
David Whiscombe asks whether it is fair for a taxpayer to be effectively taxed twice on the basis of a mutually exclusive analysis of the same transaction.
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