Andy Keates
Member Since: 30th Jun 2017
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Tax writer
27th Oct 2020
Top slicing relief piles up more trouble
Top slicing relief (TSR) is used when an individual cashes in non-qualifying life assurance policies (commonly called bonds) to create a...
Personal tax
28th Aug 2020
Domicile question is key to tax enquiry
Former Shell executive Evert Henkes (TC07645) had filed his tax returns on the basis that he was domiciled outside the UK, so any non-UK...
Personal tax
30th Jul 2020
Data demanded from tax investigation specialist
HMRC can require taxpayers to produce information and data by issuing data-holder notices (FA 2011 Sch 23) and information notices (FA 2008...
Business tax
18th Jun 2020
Fifty shades of HICBC: Courts play penalty lottery
Virtually all the FTT cases concerning the high income child benefit charge (HICBC) involve appeals against penalties charged for failing...
Personal tax
28th May 2020
How tax advisers can be negligent
Cases of professional negligence frequently turn as much on what was not said as on what was said. Hurlingham The leading case is...
HMRC & policy
20th May 2020
IHT: No relief on £976,781 gift to UKIP
Banks wished to obtain IHT relief under IHTA 1984 s24 (gifts to political parties). Relief was denied because, under the rules specified in...
Personal tax
5th May 2020
Pension election accepted, nine years late
Peter Hayes (TC07586) missed the deadline of 5 April 2009 for registering his pension for “lifetime allowance protection” (FA 2004 Sch 36...
Personal tax
14th Apr 2020
Tax scheme promoters scuppered by own scheme
The Alchemy scheme is a complex tax avoidance scheme using a combination of spread bets on financial markets to benefit directors and their...
Business tax
12th Mar 2020
Budget 2020: Excess pension contribution charges eased
It would have been too much to expect a draft Finance Bill to be published which did not include some tinkering with the pension tax regime...
HMRC & policy
4th Mar 2020
Stale discoveries lead to failed assessments
Where there is an unreasonable delay between HMRC’s discovery that insufficient tax has been charged and issuing an assessment, the...
HMRC & policy