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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....
The return of the inspector
In the November 2019 issue of Tax Adviser, ‘An inspector calls’, I discussed the High Court’s dismissal of a judicial re...
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Perils of an unauthorised payment
The taxation of pension schemes was thoroughly overhauled in the Finance Act 2004 with the new rules coming into force o...
Terminator 2
Although always a business risk, the current Coronavirus crisis is likely to have caused (or will lead to) the early ter...
Not only… but also
This article concerns a case which considered the Limitation Act 1980, which applies only in England and Wales....
Partners in tax
As I noted in my January 2020 article ‘What a carry-back!’, there remain a number of unresolved questions concerning the...
An officer and an automaton
Over the past few years, doubts have been raised about whether the Taxes Management Act (TMA) 1970 has kept up with HMRC...
A golden contract
The concept of enterprise zones (EZs) was born in the first year or so of Mrs Thatcher’s premiership....
What a carry-back!
When working on the Tax Law Rewrite Project at the turn of the millennium, I was told that there had been a recent deleg...