Private residence relief – Married couples ‘living together’ for CGT purposes

Married couples (and civil partners) benefit from favourable treatment for certain tax purposes. A common example is the ‘no gain, no loss’ capital gains tax (CGT) treatment for inter-spouse... Read more

Ownership and tax issues – HMRC guidance on constructive and resulting trusts

It is straightforward in most cases to establish an individual’s income entitlement for tax purposes. However, there are exceptions. HM Revenue andCustoms (HMRC) recently issued new guidance in its... Read more

Penalties and costs – The taxpayer fights back

Taxpayers have recently been successful in a number of appeals before the tax tribunal on the grounds of ‘reasonable excuse’, mainly in respect of late filing penalties. One such case is highlighted... Read more

HMRC Information notices

Taxpayers can be required to provide HM Revenue and Customs (HMRC) with certain information and/or documents, if HMRC issues a written notice to that effect (FA 2008, Sch 36, para 1; previously TMA... Read more

Assessments and appeals - What can taxpayers appeal against?

It is normally straightforward to tell when HM Revenue and Customs (HMRC) have raised an assessment in respect of a taxpayer. However, what constitutes an ‘assessment’? This is an important question... Read more

HMRC Enquiries

When a HMRC enquiry notice into a tax return arrives, it is perhaps natural to anticipate a long, drawn out process to completion. This is particularly the case with full (as opposed to aspect)... Read more

Intangible Fixed Assets

An important potential advantage of trading through a limited company (as opposed to a partnership or sole trader) is the availability of tax relief for the amortisation of goodwill under the... Read more

Beneficial Ownership: Mark McLaughlin Discusses CGT

It ought to be straightforward enough to identify who has made a disposal for Capital Gains Tax (CGT) purposes. Of courses, tax is seldom black and white. The tax legislation offers little help. It... Read more

HMRC and Agents

HMRC caused a stir on 31 May 2011, with the issue of the consultation document 'Establishing the future relationship between the tax agent community and HMRC'. HMRC's proposed strategy includes... Read more

IR35: The Saga Continues...

Hopes were raised that the Government would take the opportunity in the Budget on 23 March 2011 to abolish IR35 – the intermediaries legislation variously described as the ‘personal service company’... Read more

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