Two recent tax cases heard by the First-Tier Tribunal show that the courts continue to interpret the phrase “reasonable excuse” more generously that HMRC internal guidance allows for. In S Taylor, a taxpayer was somewhat …

Recent tax case law has brought out some interesting points on how the Courts view operational issues. 1. Tax avoidance schemes associated with the film industry seem to follow inevitably (with various complications) from the …

A recent case on trading losses could have implications going forward as it was found that, in the specific circumstances, losses from an acquired trade could be used against profits from the existing trade. The …

In the recent case of J Day & A Dalgety, two taxpayers had sold three properties that they owned together. The case concerned negligence and penalties for carelessness, as they did not include any details …

More cases on the scope of HMRC powers. The first concerns a current successful barrister.  His penalty for failing to react to HMRC information notices was £1.2m+.  Many would say “Ouch!  That hurt!”  However, in …