HMRC Unsuccessfully Challenges Tax Reducing Rectification
The England and Wales High Court (EWHC) has agreed to rectify two deeds of appointment made in 2013 that mistakenly terminated Nicholas Ware’s life interest, a qualifying pre-March 2006 life interest, in the assets of his late father, when they…
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Trust Registration Deadline Extended for Non-Taxpaying Trusts
HMRC have confirmed that the March 2021 target for upgrading the Trust Registration Service (TRS) to allow non-taxable trusts to register will not be met. The general requirement for all express trusts to register on the TRS was introduced by…
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British family sells $10m Van Gogh to avoid rise in capital gains tax
A British family are selling a Vincent Van Gogh drawing for a record breaking $10m (£7.1m) to avoid a potential rise in capital gains tax in the budget on Wednesday 3rd March. Thomas Gibson, a London art dealer, and…
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Inheritance Tax & Covid-19
Welcome to February! According to the latest HMRC figures published, inheritance tax receipts hit a five-year high in the final quarter of 2020. Receipts steadily rose from August onwards and peaked at a five-year high in October 2020. While this…
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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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