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Paradise lost; paradise regained
In the October 2019 issue of Tax Adviser, I considered the decision of the First-tier Tribunal in the case of Hoey....
BAD timing: the need for clarity
Business asset disposal relief (previously known as entrepreneurs’ relief) has many critics.
They think it’s all Uber
The Uber case (Uber BV v Aslam [2021] UKSC 5) was not a tax case.
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Terms of procurement
The transfer of assets abroad (TAA) legislation is one of those long-established anti-avoidance provisions that should n...
Back to the past
I should make it clear that this is a case with which I had some background involvement.
Six to eight weeks
The exemption from capital gains tax in respect of a taxpayer’s only or main residence is perhaps the widest known tax r...
The third Wiseman
One of my earliest tax memories was the announcement in the 1988 Budget concerning the proposed introduction of ‘indepen...
Fatal distraction
One of the things I discovered during my legal studies was that the High Court has the power to correct mistaken documen...
On the way to the forum…
Over the past decade or so, a procedural issue that has arisen from time to time is whether or not proceedings have been...
Back to basins!
Subject to the usual caveats about making generalisations, tax disputes can typically be divided facts are....