Harriet Brown

Harriet is qualified to practice in England and Wales and Jersey. She appears in courts and tax tribunals regularly. She advises in relation to direct and indirect taxes, frequently in the context of individuals and trusts. Additionally, she has particular expertise in international matters such as double tax treaties, TIEAs, FATCA/CRS disclosure facilities and conflict of laws issues arising in a tax context.

Harriet is also experienced in resolving disputes with HMRC. Her approach is always to give detailed and practical advice from the initial enquiry through to any tribunal hearing, which often results in a favourable conclusion at an early stage and always aims to achieve a quick and cost-effective solution.

Harriet’s Jersey practice primarily involves advising on Jersey trusts and tax in Jersey. She has particular expertise in relation to trust remedies in Jersey (including the statutory mistake and “Hastings-Bass” regimes) and Jersey income tax.

Harriet is licensed to accept instructions under the Public Access Scheme.

Typical matters on which Harriet has been asked to advise include the following:

• HMRC enquiries involving domicile, the transfer of assets abroad, HMRC’s powers of recovery outside the UK, employment taxes and taxation of charities.
• Employee taxation including the scope of the benefits code, the disguised remuneration legislation (Part 7A ITEPA 2003) and the Rangers case.
• Pensions taxation, including taxation of international pensions (QROPS) and all elements of UK-based pensions taxation (FA 2004, Part 4).
• Non-resident trusts.
• Residence, domicile and the taxation of foreign domiciliaries.
• Inheritance tax planning.
• Taxation of charities and gifts to charities.
• FATCA and CRS.