Issue: Vol 167, Issue 4287

6 Jan 2011

IN THIS ISSUE

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MICHAEL RIPLEY believes the ECJ’s decision in the AXA case creates more uncertainty than clarity

ANDREW SHAW considers the increasing importance of commercial reality over legal form when advising on EBTs and EFRBS

MIKE EVANS offers an insight into the new CIS penalty structure and what affected businesses might do now to avoid paying excessive sanctions

CHRIS CHADBURN reviews the National Audit Office report on HMRC’s management of civil tax investigations

A client in his mid-60s has an investment property portfolio which is subject to mortgages. He is considering the transfer of properties, but not mortgages, to his children

A husband and wife live in different properties, although they have not formally separated and they do holiday together

A client applied to join the VAT flat-rate scheme from 1 October 2010, but HMRC have shown a date of 1 October 2009 when confirming that the scheme may be used

A mother, father and their two sons trade as a partnership and are considering whether they could mitigate their tax liability by including a limited company as a partner

Extracting cash from a company; impact of US tax law on UK assets; paying interim dividends; formalising the sub-letting of a limited company

Removal of warnings of no legal force

HMRC acknowledges stock exchange

DTA amendment

Temporary measure to run to end of February

Hansard, 9 Dec 2010, vol 520, no 88, col 368W

Amendments to provision in Offshore Funds (Tax) Regulations 2009

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