Continue reading "Disclosure: Behind closed doors"
Wood v HMRC [2016] UKUT 346 (TCC)
Wills & Trusts Law Reports | October 2016 #163In June 2010, Michael Wood admitted to under-declarations of income tax for the years 2002-03 to 2007-08 amounting to £743,424 and made a payment of tax of £352,983. This was made with a view to taking advantage of an HMRC disclosure opportunity for medical professionals called the ‘Tax Health Plan’, with a fixed tax geared penalty of 10% of the amount of tax under-declared. HMRC argued that the disclosure fell within the Tax Health Plan and opened a Code of Practice 9 investigation into his affairs. Michael Wood agreed to provide a disclosure report (the disclosure report) into his affa...
Edwards-Moss & anr v HMRC [2016] UKFTT 147 (TC)
Wills & Trusts Law Reports | July/August 2016 #161This appeal concerned the estate of Lady Edwards-Moss (the deceased) who died on 8 February 2007. The executors of her estate appealed against a determination under s221 IHTA 1984. HMRC argued that the liability arose on two alternative bases. First, the transfer of a freehold farm in return for an annuity on 23 January 2007 (very shortly before her death) was ineffective (either on the basis that it was legally ineffective or under the reservation of benefit rules). Alternatively, this was a transfer at an undervalue, and therefore a transfer of value on which an IHT liability ...
Disclosure: Show and tell
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Dawson-Damer v Taylor Wessing [2015] EWHC 2366 (Ch)
Wills & Trusts Law Reports | March 2016 #157Taylor Wessing LLP (TW) are the London solicitors of Grampian Trust Company Limited (the trustee), a company resident and incorporated in the Bahamas. The trustee is trustee of a discretionary settlement known as the Glenfinnan settlement, settled in 1992 and governed by Bahamian law. The Glenfinnan settlement was a resettlement of certain funds from an earlier Bahamian settlement (the 1973 settlement). The first claimant is a beneficiary of the Glenfinnan settlement. The second and third claimants, her children, are not beneficiaries. In 2006 and 2009 the trustee made substantial appoin...
Disclosure: What makes data ‘personal data’?
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Non-Disclosure: Facing the music
T E
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Disclosure: Differential discovery
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Disclosure: Nowhere to run, nowhere to hide
Continue reading "Disclosure: Nowhere to run, nowhere to hide"
Disclosure: On a roll
Continue reading "Disclosure: On a roll"