Tax Schemes & ‘Tales of the Unexpected’
There were reputedly 30,000 “home loan” or “double trust” schemes implemented in the late 20th and early 21st centuries and as people die these schemes have been increasingly challenged by HMRC since about 2011. The ‘home loan’ arrangement in the case…
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What’s New in Tax for 2021 at Stephen Parnham Taxation?
My Best Wishes for a happy, healthy and prosperous 2021. My 2021 reviews and reports for taxpayers concerned about inheritance tax are now available on the website. These include The Fixed Fee Inheritance Tax Review 2021 For that first decisive…
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Scottish holiday accommodation loses BPR despite service provision
A legatee who inherited her father’s furnished holiday accommodation business failed to persuade the First-tier Tax Tribunal that it was ‘relevant business property’ for the purposes of business property relief under the Inheritance Tax Act 1984 (IHTA). The property was…
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The Office of Tax Simplification Proposals Regarding CGT: Business Issues
The first part of this blog (posted 16 November) focussed on those elements of the proposals pertaining to the private client sphere. I now turn to those which could impact on the business and entrepreneurial spheres. Taxing Share Sales…
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The Office of Tax Simplification Proposals Regarding CGT: Private Client Issues
Rather surprisingly, the Office of Tax Simplification (OTS) has rushed out its initial report on capital gains tax (CGT). The report was issued only two days after the closing date for submissions and despite the fact that the Government has…
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The Future of Capital Gains Tax
On 14 July the chancellor wrote a letter to the Office of Tax Simplification requesting it “undertake a review of capital gains tax”. Interestingly, there was no announcement of the letter on the Treasury website. The tone of the correspondence…
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Third-Party Notice Powers: No Right of Appeal?
There are circumstances where HMRC has a legitimate need to directly approach financial institutions to obtain tax related information where taxpayers are unwilling or unable to do so. As things stand, HMRC has the power to issue a Schedule 36…
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Trustees Granted Additional Powers For Inheritance Tax Planning
The High Court has agreed to grant additional powers to the trustees of a family settlement for the purposes of Inheritance Tax planning in the case of Cotterell & Anor v Allendale & Anor [2020] EWHC 2234. Trustee Act 1925 s…
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Gift Ruled to be a Transfer of Beneficial Ownership
This is an interesting case for anyone involved in issues/disputes over legal and beneficial ownership. It includes a useful review of relevant case law and clearly emphasises the importance of the circumstances and facts. The England and Wales High Court…
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Lockdown & Wills: The Latest
Lockdown has prompted the government to update the 183-year-old rules on witnessing wills. But some solicitors think reform is unnecessary and risks creating a contentious probate spike. Wills have stubbornly resisted the digital world. While many legal documents, including deeds…
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