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APPEALS


Andrew Goldstone and Sarah Albury (Mishcon de Reya) review the latest developments that matter in the private client arena, including: HMRC’s hat trick of wins in cases against schemes promoted by NT Advisors; a consultation on VCTs; Lobler and rectification for the partial surrender of insurance policies; online filing of IHT accounts from August; and Tager and punitive tax-related penalties

Discount on stripped coupon security

Tax fraud involving pension funds

What are statutory records?

Actions have consequences: for HMRC as much as for taxpayers, writes BKL Tax

HMRC’s ability to enter into binding agreements

Mistake by the taxpayer; appeal allowed

Gideon Sanitt (Macfarlanes) considers the decision in Ingenious Media and when HMRC may be excused from its duty of confidentiality.

David Pickstone (Stewarts Law) reviews the recent Upper Tribunal decision in Ingenious, which considered whether HMRC could make allegations of dishonesty at a late stage in proceedings without having pleaded them in its statement of case.

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