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Gulliver's travails
After HMRC’s onslaught in the first decade of this century on taxpayers who claimed to have been non-UK resident, I alwa...
For whom the bell tolls
In my article ‘Whose claim is it anyway?’ in the January 2015 issue of Tax Adviser, I wrote about the taxpayers’ success...
The Crown and the Cushion affair
Imagine a client coming in with this great tax-saving idea.
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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...
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...