Rebecca Sheldon

Rebecca has recently advised on the following issues:

• Prospects of success when considering appealing to the First Tier Tax Tribunal, the Upper Tax Tribunal and the County Court;
• Whether to accept an independent review of a HMRC decision;
• A1 certificates and the rules surrounding the overseas daily allowance in the context of employee taxation and Brexit;
• The availability of VAT input tax credits;
• VAT leasing structures;
• Halifax principle of abuse in a VAT context;
• Law and procedure for opting to tax for VAT in the context of leases;
• VAT penalties and interest;
• 1614D VAT certificates;
• The concept of “abuse” in a VAT context;
• SDLT and the potential reliefs available, including group relief;
• Law surrounding the calculation of consideration for SDLT purposes;
• The availability of principal private residence relief for CGT;
• Entrepreneurs relief;
• Non-resident trusts and capital gains tax;
• The law and procedure for appointing new trustees;
• Challenging wills;
• Perpetuity and accumulation issues;
• IHT and CGT consequences in the context of different types of trusts, exit charges and 10-year charges;
• Taxation of discretionary trusts involving non-resident and UK resident beneficiaries;
• Drafting documents;
• Drafting trusts;
• Penalty notices and closure notices;
• Failure to notify penalties;
• Without prejudice communications;
• Council tax exemptions;
• High Income Child Benefit Charge;
• Residence rules including split-year treatment;
• Citizenship;
• Double tax treaties;
• The Transfer of Assets abroad legislation;
• The “settlement” legislation;
• Gift with reservation of benefit rules;
• Residence nil rate bands and transferable nil rate bands;
• Double trust home-loan schemes;
• Advice concerning section 25A of the Commissioners for Revenue and Customs Act 2005, and;
• IHT, CGT, SDLT and VAT consequences in the context of property partnerships.

Litigation has included:

•  An FTT hearing concerning the availability of principal private residence relief (Adams v HMRC [2020] UKFTT 56 (TC) );
• An application for permission for a late appeal to the FTT;
• Appearing for the taxpayer to object to HMRC’s application for summary judgment under Part 24 of the CPR, and;
• Appearing for the Claimant to prevent the strike out of their claim.

Rebecca also has experience of (where appropriate):

• Settling at the court door, and;
• Negotiating settlements.

R Sheldon, ‘Dong Yang Electronics Case C-547/18’ 2020, British Tax Review (forthcoming)

R Sheldon, ‘Fisher v HMRC’ 2020, Tax Adviser (forthcoming)

R Sheldon, ‘Coyle Transport v HMRC’ 2020, British Tax Review (forthcoming)

R Sheldon, ‘Arron Banks v HMRC’ 2020, Taxation

R Sheldon, ‘Summary of the House of Lords Economic Affairs report on IR35” 2020, OSTC

R Sheldon, ‘The remittance basis‘ 2020, OSTC

R Sheldon, ‘Tax on overseas properties: which laws apply?‘ 2020, OSTC

R Sheldon, ‘A stable proposition?’ 2020, Tax Adviser

R Sheldon, ‘The tax plans of the major parties,‘ 2019, Key Haven Tax Review

R Sheldon, ‘Limits to Upper Tribunal jurisdiction,’ 2019, Taxation

R Sheldon, ‘All or nothing: Embiricos v Revenue and Customs Commissioners [2019] UKFTT 236 (TC)’ 2019, Tax Advisor Magazine

R Sheldon, ‘Praesto Consulting UK Ltd v HMRC [2019] EWCA Civ 353‘ 2019, British Tax Review

R Sheldon, ‘Finance (No.2) Act 2017 Notes: Section 68: penalty for transactions connected with VAT fraud etc,’ 2017, British Tax Review

R Feria and R Sheldon, ‘Italmoda: the birth of the principle of third-party liability for VAT fraud,’ 2016, British Tax Review

‘Covid 19 and the relaxation of UK residence rules’ Key Haven (forthcoming)

‘Private client tax developments’ at OSTC London seminar (13th November 2019)

‘The Labour Party’s Tax plans’ Key Haven Oxford Conference Speaker (1st October 2019)

‘VAT and Brexit’ EANOVAT Roundtable speaker (6th September 2019)

‘VAT update 2019 webinar‘ co-hosted with Etienne Wong for Lexis Nexis (4th July 2019)

‘The Appeals Process’ at OSTC Manchester seminar (22nd May 2019)

‘Taxation of Non-Resident Company Landlords (compliance aspects)’ led by Sarah Squires for Paul Hastings (22nd March 2019)

‘Taxation of trusts’ for the London Tax Society (4th March 2019)

Co-author of Ray & McLaughlin’s “Practical Inheritance Tax Planning” (forthcoming)

Contributor to “Tax Planning” 2019/20 (forthcoming)

Co-editor of Wolters Kluwer’s “A Handbook of EU VAT Legislation” (forthcoming)

Online moderator for James Kessler QC’s “Taxation of Charities and Non-profit Organisations“

The Buchanan prize for gaining an “Outstanding” grade on BPTC (Lincoln’s Inn)

The Kate Bertram First Class award for achieving a first class grade in the LL.M (University of Cambridge)

Becker law award (University of Cambridge)

Maria Marina award (University of Cambridge) 

The Lord Mansfield scholarship for the BPTC (Lincoln’s Inn)

The Hardwicke award (Lincoln’s Inn)

The Sweet & Maxwell “best final year performance” award (Durham University)

Lady Hale prize for “best gender & law dissertation” (Durham University)

Durham University commendation 2015 (Durham University)

Land law prize (2nd place) (Durham University)

Durham University commendation 2014 (Durham University)

Revenue Bar Association

Chancery Bar Association

The Contentious Trusts Association (ConTrA)

Frequent volunteer for Advocate, involving both advisory work and litigation