tax – Law Journals

Tax: Operative mistakes and unintended consequences

Lawrence Hiller-Wood and Richard Dew discuss the High Court’s current approach to setting aside mistakes Care should always be taken when dealing with or amending pre-2006 interests in possession to ensure that there are no unintended or costly consequences. The recent High Court decision in Hopes v Burton [2022] is a helpful reminder of the …

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Tax: Taking it over the line

Firth sheds light on the inheritance tax treatment of furnished holiday lettings. Dr Christopher McNall discusses the case The key issue is whether property is ‘relevant business property’, so as to qualify for BPR, or simply part of the business of holding land, being ‘wholly or mainly… making or holding investments’. Business property relief (BPR) is …

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Guest editorial: Will there be a further U-turn?

Kwasi Kwarteng announced the abolition of the OTS in his recent mini-budget. Judith Millar explores what this means for private client practitioners As a private client practitioner, regularly grappling with layers of tax complexity, and particularly in the light of the Treasury’s endorsement less than a year ago, the recent announcement about the closure of …

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Trusts: Shedding light on remuneration trusts

Mary Ashley reports on a rare taxpayer win Cases like Marlborough are helpful to reveal how HMRC will form its arguments when it wants a tribunal to look at the overall effect of an arrangement rather than the detail. Marlborough DP Ltd v The Commissioners for Her Majesty’s Revenue & Customs [2021] is a First-tier …

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Musings from Manchester: What do we want?

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Succession and tax are interlinked. Geoffrey Shindler makes the case for reviewing the underlying principles behind both when considering change Would it not be a good idea to deal with tax and succession at the same time as the two are inherently closely interlinked? I set out below something I have recently read with interest. …

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Tax: The future of CGT?

Ramandip Kaur and Jo Summers provide a review of the OTS’s second report on CGT The OTS is recommending that a Single Customer Account for all taxpayers, which is easily accessible and secure, should be a key component of the government’s vision, particularly for CGT. The Office of Tax Simplification (OTS) is the independent adviser …

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Tax: Planning for the future in the present

Rosalind Fitzgerald and Sofia Thomas discuss the practicalities of ‘nesting’ child arrangements and the tax issues that may arise In a nesting arrangement, if both parties are going to utilise the second home for some time, it may well make sense to transfer the property into joint names, so that the annual CGT exemption for …

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