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The best tax and trust barristers for high-net-worth individuals

The barristers listed below have been selected by Spear’s for their proven excellence in the field

Tax Controversy Update: September 2021

This edition focusses on HMRC’s approach to Wealthy individuals, how this is changing and how your wealthy clients can better prepare for interactions with HMRC.

US indicts 6 foreign nationals, Swiss firm over USD 60 m tax fraud

Indictment Alleges that Defendants Conspired to Help U.S. Clients Evade Taxes on More Than $60 Million Hidden Offshore

Court of Appeal gives guidance on mutuality of obligation for employment tax status

The fact that the overarching contract is not a contract of employment and there is no obligation under the overarching contract to offer work, or to do work if offered, does not mean that the single engagement cannot be a contract of employment.

A Review of TJN's Financial Secrecy Index

This review seeks to understand better what led to Cayman being ranked first on the 2020 FSI

Overview of US Tax Provisions of Build Back Legislation Approved by House Ways & Means Committee

The legislation has a way to go before it is enacted into law but nonetheless provides an overview of changes likely to find their way into the Internal Revenue Code.

Complaints of delays in the UK’s first-tier tax tribunal

At present in a tax case there are four levels of appeal, with cases starting in the FTT, then progressing to the UT, Court of Appeal and Supreme Court, if permission to appeal is granted at each stage.

Gift planning opportunities for US persons in the UK

In any event, even under current law, the unified exemption amount will automatically decrease to $5 million (plus an inflation adjustment) come January 1, 2026.

Tax consequences of volume ownership

The new concept of “volumes” refers to a geometric space of three dimensions, geographically located at a well-defined place.

Employment tax issues that not-for-profit organisations need to be aware of

There is no tax and NIC applied to purchases made by employees for home-office equipment until 5 April 2022 due to the Coronavirus pandemic.

FOI request reveals HMRC owes millions after landmark 'round the world' case

The follower notice tells P that they may be liable to a penalty of up to 50% of the tax and/or NICs in dispute if they do not amend their return or settle their dispute."

Cyprus Tax Department publishes updated XML Schema for DAC 6 reporting

Once the XML files are completed they should be submitted on the CTD’s electronic government gateway portal (known as Ariadni).

EY fined more than £2m over audit failings

Big Four firm and former partner receive severe reprimands from UK accounting watchdog

Richard LeVine featured in Wall Street Journal article on off-shore tax shelters

Richard adds that in addition to an IRS crackdown, the Treasury Department could seek changes to the Malta treaty.

Middle East & North Africa: Handling transfer pricing disputes in MENA - The shape of water

Against this backdrop, the Middle Eastern economies are battling lower oil prices and budget deficits, which in turn increase the pressure for fiscal receipts.

UK taxpayer prevented from challenging validity of tax enquiry

The Supreme Court, in its judgment, found that the legal concept of ‘estoppel by convention’ applied in this case.

Tax havens meet monopoly power: why national competitiveness harms competition

There is more than one possible answer, but in many countries a “Competitiveness Agenda” holds sway.

Global Legal Insights Corporate Tax 2021: Luxembourg

The Luxembourg Court has also issued several decisions, which addressed challenges by the Luxembourg tax authorities of periods following the entry into force as of 1 January 2015 of the formal ruling procedure.

Third party tax information notices taxpayers have no right to attend hearing

The third party will usually be notified in advance that an application for the issue of a notice is going to be made and will have an opportunity to submit representations regarding the information required.

‘Avatar’ Film Funding Firm Backed by David Beckham, Sacha Baron Cohen Wins $975 Million Tax Avoidance Case Against HMRC

Ingenious therefore created film finance partnership schemes – which funded some of the world’s most successful films