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All’s well that ends badly
In my April 2013 article in Tax Adviser ‘Much Ado about Something’, I wrote about the appeal by JP Whitter (Waterwell En...
Basic Instinct
A few years ago, the CIOT/ATT London Branch annual dinner had as its guest speaker Lord Justice Carnwath (now Lord Carnw...
Family fortunes
In one of the first cases I ever argued before the (now defunct) General Commissioners, I had been instructed by the dir...
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The Karate Kid
Facts of the case The business, Karate World, provides instruction in martial arts.
Return of the naïve
The facts of the case In May 2008, the taxpayer (‘Mr Hardy’) entered into a contract to purchase a leasehold property, ...
Pro-holy and pro-Fane
One of the novelties of the penalty provisions found in FA 2007, Sch 24 (penalties for inaccurate tax returns etc) is th...
Jigsaw puzzle
In my article ‘La Peine Quotidienne’, Tax Adviser, February 2015, I discussed the penalty rules for late tax returns, as...
The Terminator
It is well known that termination payments made to employees can often escape tax, subject to a cap on the exemption of ...
Much ado about nothing
Advisers will know that for entrepreneurs’ relief to apply on the disposal of company shares, other than EMI shares, the...
A Comedy of errors
For many years, the necessary conditions for a discovery assessment were well known and understood.