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Rayner my parade! The importance of specialist advice.
Jemma Brimblecombe
Others may be on holiday in August, but not HMRC, who chose August 2014 to take taxpayers by surprise and change their stated position, with immediate effect, on the taxation of foreign income and gains used by UK resident, non UK domiciled individuals claiming the remittance basis (Remittance Basis Users - “RBUs”) as security for loans used in the UK.
Gary Barlow and two fellow Take That singers have found themselves in the spotlight this week after a judge ruled the musicians had invested in a scheme designed for tax avoidance purposes. Not only may they have to pay back millions of pounds in tax after the tribunal ruling but they have also suffered considerable reputational damage as a result.
This article first appeared in MusicWeek.
The Court of Appeal has published its eagerly anticipated (by tax geeks at least) judgment in the case of HMRC v The Executors of Lord Howard of Henderskelfe (deceased) ([2014] EWCA Civ 278).
In the First Tier Tribunal case of TC03273: Jeremy Rice, a car salesman was allowed to claim Entrepreneur’s Relief on the sale of his premises when he closed his business and started up elsewhere. The relief was claimed on the basis that it was a sale of a business asset within three years of cessation of trade.
An investment banker working on a deal in Belgium failed to convince the Court that he was non-resident for tax purposes in the First Tier Tax Tribunal case of Paul Daniel (TC03312).
Jemma Brimblecombe
Charles Richardson
Oliver Oldman
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