Seamus Kavanagh (FTT) (Entrepreneurs Relief, whether 5% shareholding for ‘personal company’, whether trust of shares (express, resulting or constructive)
Oisin Fanning [2022] STC 256 (SDLT planning and grant of option) (PTA to CA)
Mark Mitchell & Paul Bell [2021] UKUT 250, [2020] UKFTT 102 (TC) (HMRC seeking to rely on documents confidential to one appeal in joined VAT appeals involving Personal Liability Notices concerning one appellant – first appellant objecting – decision based on relevance of material – application allowed in part before FTT; UT refused second appellant’s appeal (application PTA to CA)).
Bhaur & Others v IVM PCC & Others (Chancery Division) [2021] EWHC 2581 (Part 8 Claim, Application to set aside non-UK employee benefit trusts on basis of mistake claim (Pitt v Holt))
Kingsley Douglas v Revenue and Customs [2021] UKUT 163. Validity of VAT best judgment assessments.
M&M Builders (Norfolk) Limited v HMRC [2021] STC 975, [2021] 4 WLR 83. Annuity given as consideration for purchase of property, whether s.52 (annuity provisions) or s53 (sale involving a company) applied to determine taxable consideration.
Mark Shaw (as nominated member of TAL CPT Land Development Partnership LLP) v Revenue and Customs [2021] STC 1144: whether Industrial Buildings Allowances available.
Hannah, R (On the Application Of) v The Taxation Disciplinary Board Ltd [2021] EWHC 1069 (Admin): whether Chartered Institute of Taxation is a public body, and whether referral of a CIOT member to the Taxation Disciplinary Board was in breach of natural justice.
Hannah & Anor v Revenue & Customs [2021] UKUT 22 (SDLT – whether annuity sole consideration for house purchase, ss. 52, s.75A) [2019] UKFTT 342 (TC)
Mobey v Revenue and Customs (STAMP DUTY LAND TAX-Multiple Dwellings Relief-whether relief available for annexe to main building) [2021] UKFTT 122
Kevin McCabe v HMRC (23 ITL Rep 267, [2020] BTC 561, [2020] STC 2148) (whether to direct HMRC to disclose documents relating to a “mutual agreement procedure” with the Belgian tax authorities pursuant to the UK/Belgium double tax treaty)
Hopscotch Ltd v HMRC [2020] STC 2313 (Upper Tribunal considered whether the redevelopment of residential property was part of a property development trade for the Annual Tax on Enveloped Dwellings (ATED). The UT decision contains an evaluation of the “badges of a trade” and the distinction between an investment company and a trading company.
Development Securities (No.9) Ltd & Others v HMRC [2021] 2 All ER 163, [2021] 4 WLR 4, [2021] STC 84, [2019] STC 1424 (UT) (won on appeal from FTT, reversed in CA) (corporate tax residence / Jersey / UK / dual residence)
MCX Dunlin (UK) Ltd v Revenue And Customs [2020] STC 318 (Ch) (13 January 2020) (whether repayments were Advance Petroleum Revenue Tax or PRT; represented HMRC)
Albert House Property Finance PCC Ltd & Anor v Revenue & Customs [2020] UKUT 373 and [2019] UKFTT 732 (TC) (3 December 2019) (whether SDLT appeals validly withdrawn)
Newton & Anor v Revenue & Customs [2019] UKFTT 688 (TC) (SDLT – whether discovery – whether subsale relief applied) 12 November 2019 (subject to PTA)
Turners (Soham) Ltd v HMRC [2019] STI 959: computation of trading profits / application of statutory renewals allowance; whether trucks and trailers “tools”
High Court (Garnham J) and Court of Appeal (2019) (subject to reporting restrictions / Contempt of Court Act 1981)
Pulsin Ltd v HMRC [2019] STI 222 – represented HMRC, whether product an item of “confectionary” or a “cake” for VAT purposes.
DAC Beachcroft v HMRC [2018] UKFTT 0502 (TC): Information notice, application of legal professional privilege, Information Notice: Resolution of Disputes as to Privileged Communications Regulations 2009
Judicial review / tax related criminal investigation (subject to reporting restrictions / Contempt of Court Act 1981)
National Federation of Occupational Pensioners v HMRC [2018] STI 390: VAT / unincorporated associations / whether separate person for VAT
Frosh, Joyce, Goring-Thomas v HMRC [2017] STC 1941 (UT) (closure notices / effect of invitation to settle letters)
X v Y: defence to professional negligence claim against tax advisers
Travel Republic Limited v HMRC [2018] EWHC 3905 (Admin): VAT treatment of credit card fees / ancillary to principal supplies / Business Brief 18/06 / legitimate expectation
Omega LLPs v HMRC: represented HMRC in FtT / partnership tax appeal / stay application