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Harriet Brown


Harriet was called to the Bar in 2005, before moving to Jersey to practise as a Jersey Advocate, advising on the offshore aspects of both trust and corporate structures.

She litigates in the English courts and tribunals as well as in Jersey in relation to both purely tax matters, as well as matters with a tax element. She advises on all aspects of direct and indirect taxation (including matters with an offshore element), as well as on Jersey law.

Harriet is a former editor of the Personal Tax Planning Review and the Offshore and International Tax Review. She is a co-author (with Rory Mullan) of "the Interaction of EU Treaty Freedoms and the UK Direct Tax Code" and was formerly a co-author of "the Taxation of Charities" (with James Kessler QC). Her own book, "the Jersey Law of Trusts", will be published later in 2012/2013.

Cases

Some of Harriet's recent cases include:

Re A [2012] UKFTT 541 (TC)

Fisher v Revenue and Customs Comrs [2012] UKFTT 335

Chappell v HMRC [2012] UKFTT 453 (TC)

Benest v Syvret (as executor of Dorothy May Benest) [2012] JRC 079A

Countrywide Estate Agents FS Limited v HMRC [2012] STC 511

Price v HMRC [2011] UKFTT 624 (TC)

Countrywide Estate Agents FS Limited v HMRC [2010] UKFTT 263 (TC)

H v H [2010] EWHC 158 (Fam)

In the matter of the representation of Andsberg Limited [2007] JRC 179, [2009] JLR Note 53

Articles

Domicile and the Capital Taxes Treaties – OITR, Volume 14

Ashcroft v Barnsdale: Tax Consequences and Rectification Revisited – PTPR, Volume 13

A Cautionary Note on Explanatory Notes - PTPR, Volume 13

Correcting Mistakes: Ashcroft v Barnsdale and rectification – Taxation, 22 September 2010

Queensbury Rules - the HMRC Internal Review Procedure One Year On - Taxation, 25 March 2010

The Development of Hastings-Bass in Jersey – Trusts Quarterly Review, Volume 8, Issue 2

Taxation of Deemed Dividends under Jersey Law: the Changing Face of Taxation in a Low Tax Jurisdiction - OITR, volume 14

Charities and variation of wills - Trusts Quarterly Review, Volume 8, Issue 1

Considering the UK Tax Implications for Jersey Foundations – Tax Adviser, January 2010

The Transparency of Jersey Partnerships and Certainty when Planning – OITR, volume 14

Books

Jersey Law of Trusts, 3rd Edition

Taxation of Charities 7th edition (with James Kessler QC)

The interaction of the EU Treaty and UK Tax Code (with Rory Mullan)

Publications

Contributor to CCH's Tax Planning in 2009/10

Contributor to Tolleys Property Taxation in 2009/10

Contributor to Tolley's Tax Planning 2009/10

Editor of the Offshore and International Taxation Review

Editor of the Personal Tax Planning Review