Posted: 19 June 2009
Issue: Online only
Categories: Miscellaneous, IT & NIC, Tax adviser, Income Shifting, Legal, Government
Keywords: Arctic Systems, Jones v. Garnett

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Library page: residence status

A run-down of Taxation news, comment and analysis of income shifting and the pivotal case of Jones v Garnett (a.k.a. Arctic Systems)

News

CIOT hails new income shifting EDM
A great opportunity for the Government, says Ellerby

Fillip for income shifting deferment
Tax sector supports Chancellor's decision to postpone new rules

CIOT blasts income shifting reforms
President voices 'extreme disappointment' in open letter to Treasury

New settlements guidance debuts
HMRC publishes Trusts Settlements and Estates Manual

Income shifting: the reactions
Notable responses to the Treasury's new consultation document

Treasury moves against income shifting
The Government has issued its long-awaited consultation document in response to HMRC's loss in the Arctic Systems case

Major CGT concessions 'unlikely'
Government 'needs every ounce of revenue it can lay its hands on to minimise overspend'

Arctic case 'cost over £500,000'
Professional Contractors Group's estimate is not recognised by HMRC

No comment on 'Changing horses' article
HMRC say it would be 'inappropriate to enter into a running commentary' on Mike Truman's 'Changing horses' piece of 30 August 2007

Post Arctic (guidance)
HMRC have recently issued initial guidance as to how they will deal with cases following the House of Lords decision in Jones v Garnett. With regard to open cases, HMRC will review all such cases and settle them in line with the decision

Well, fancy that!
During the closing stages of the House of Lords' Arctic Systems hearing, counsel for HMRC, Michael Furness QC, was asked by Lord Hoffmann whether there were any articles in learned journals on the issues raised by the case.

A chill wind
House of Lords judgment in Jones v Garnett

Taxpayer wins Arctic case
The House of Lords have found unanimously for Mr Jones in the Arctic Systems case, Jones v Garnett, upholding the Court of Appeal but on different grounds.

Arctic Systems - HL decision
First analysis of the judgments from the House of Lords

Arctic Systems
HL judgment 25 July

House of Lords: Jones v Garnett
Report of the proceedings in the hearing in the House of Lords

Arctic numbers
As the House of Lords hears Arctic Systems, the debate on how many companies are affected is likely to reignite

Out in the cold
The Professional Contractors Group has announced that the Arctic Systems hearing will not take place before 31 January 2007

Appeal sought
HMRC have confirmed that they have decided to petition the House of Lords for leave to appeal against the decision of the Court of Appeal in Jones v Garnett

Arctic Systems - Court of Appeal finds for taxpayer
The Court of Appeal has ruled in favour of the taxpayer in the case of Jones v Garnett

Arctic hearing
The appeal hearing for Jones v Garnett has been brought forward and will now be heard at the Court of Appeal in London on 29 and 30 November 2005

Arctic appeal
Mr and Mrs Jones are going to the Court of Appeal to appeal the High Court's decision in Jones v Garnett. They are being supported by the Professional Contractors Group

Arctic blast
The high-profile TA 1988, s 660A appeal, commonly known as Arctic Systems, has been lost by the taxpayer

Settlements guidance
The various tax professional bodies, including the ICAEW's Tax Faculty and the Chartered Institute of Taxation have expressed disappointment at the new Revenue guidance on the settlements legislation

Public support
Public support to fund the Arctic Systems case is being called for by the Professional Contractors Group

Section 660A appeal
The section 660A, Taxes Act 1988 appeal by Arctic Systems Ltd was heard by the Special Commissioners in London on 14-16 June 2004, and the determination is expected in about six weeks' time

Features

Income splitting
Is it still possible to reap the benefits of income sown by another? SETU KAMAL explains the current situation

Early Xmas present...
… or a ticking time bomb? FRANCESCA LAGERBERG looks at what the Pre-Budget Report really did for small businesses

Book review: Guide to the Tax Treatment of Specialist Occupations
Author: Keith M Gordon; 286 pages. Publisher: Tottel Publishing. Price: £85

Say hello, waive goodbye
MARK MCLAUGHLIN considers the application of the income tax anti-avoidance rules on settlements to dividend waivers

Income shifting shifted
Barrister KEITH GORDON of Atlas Chambers offers his initial reaction to the 2008 Budget

Income shifting round table
A discussion about the history and new proposals on income shifting, held in London on 28 February and chaired by MIKE TRUMAN

Income shifting
MIKE TRUMAN offers you a chance to have your say — if you act straight away

Income shifting consultation: main page
Have your say on one of tax's most controversial issues by adding your comments to Taxation's submission

Arctic shift
The Government has published draft legislation and guidance on income shifting. ANNE REDSTON provides an overview and suggests that a complete change of approach is required

Marriage and spoilt children
DAVID WHISCOMBE asks why HMRC chose a married couple as their 'test case' on the application of the settlements legislation

Geoff Jones and the lost Garnet(t)
MIKE TRUMAN finds the House of Lords decision in Arctic Systems even more exciting than the latest Harry Potter

Arctic at the Lords
The TAXATION EDITORIAL TEAM reports on proceedings before the House of Lords in Jones v Garnett.

Under an umbrella
KEVIN MILLER considers the various potential advantages and disadvantages that may arise from the use of a composite company

Nothing new?
JOHN WOSNER reviews the underlying principles of the Jones v Garnett case

The numbers game
MIKE TRUMAN reports on recent discussions with HMRC on the numbers of companies affected by the settlements legislation and the ongoing case of Jones v Garnett

Arctic Systems - the settlement saga
A contemporary drama in five acts by ANNE REDSTON

Director or dictator?
PETER VAINES takes another look at the decision in Arctic Systems

Poles apart
JASON PIPER and DAVID SMITH of Accountax Consulting Ltd analyse the Special Commissioners' judgment in Jones v Garnett

Comment

Fault lines
Finance Act 2008 merely adds to the fault lines in our over-complex tax system, says MIKE TRUMAN

The curious incident…
There was a strange silence on the subject of income shifting in the Budget speech. ANDREW HUBBARD puts on his deerstalker hat and investigates the reason for this

Changing horses
MIKE TRUMAN asks what HMRC know now that they didn't know in December 2005 about the Arctic Systems case

Arctic Chill
FRANCESCA LAGERBERG considers the Government reaction to the Jones v Garnett decision in the House of Lords

Icebreaker
MIKE TRUMAN looks back at the history of the Arctic Systems case, as it comes before the House of Lords for its final resolution

And the rest...
MIKE TRUMAN looks at how the decision on Jones v Garnett affects the other areas where HMRC believe the settlement provisions apply

And another thing...
MIKE THEXTON MA, FCA, CTA, weighs up the odds on the outcome of the appeal in the Arctic Systems case.

Arctic killer?
MIKE TRUMAN looks at some past articles in Taxation on s 660A and asks whether the hopes raised in them have been killed off by the High Court in Jones v Garnett

The business of human rights
JOHN WOSNER considers the possible impact of human rights legislation on the Arctic Systems decision

A sympathetic approach
MARTIN RILEY takes an alternative view of the disputed interpretation of TA 1988, s 660A

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