BN66 - Court of Appeal and beyond

[Disgusted of Coventry]

Careful!

2. There may be many definiutions but they all arrive at the same meaning - The removal of obstacles to understanding

Sorry to be pedantic, but don't underestimate HMRC's capacity to switch between precise and fuzzy language - whichever best suits their purpose at any given moment.

Their absurd argument, with s58, is that the precise wording from 1987 is itself an obstacle to understanding.

Better nail it down with "an interpretation which leads to" the removal of obstacles to understanding.

(Got that from Google!)

[Tax_shouldnt_be_taxing]

Sorry to be pedantic, but don't underestimate HMRC's capacity to switch between precise and fuzzy language - whichever best suits their purpose at any given moment.

Their absurd argument, with s58, is that the precise wording from 1987 is itself an obstacle to understanding.

Better nail it down with "an interpretation which leads to" the removal of obstacles to understanding.

(Got that from Google!)

Fair point. BTW, if you have a letter from Brannigan from early 2008 where he talks about what will happen if BN66 becomes law makes for interesting reading if you read it carefully. He said that assuming BN66 becomes law then we'd be liable to be taxed on the Partnerships. Oddly, that must mean that when he wrote the letter which was before it became law that meant we were not liable to tax on the partnership profits without BN66 being law. See where I'm going? HMRC always maintained the Scheme didn't work. Well how can that be true if Brannigan uses a condition of a change in the law as the reason for why we'd become liable?

You might sound I'm being picky but I prefer to use the word "clarify".

[Disgusted of Coventry]

He said that assuming BN66 becomes law then we'd be liable to be taxed on the Partnerships. Oddly, that must mean that when he wrote the letter which was before it became law that meant we were not liable to tax on the partnership profits without BN66 being law. See where I'm going?

Absolutely! Retrospection demands a whole new style of grammar.

Something like...

"If BN66 becomes law then you will have had been being liable to be taxed..."

[TalkingCheese]

Fair point. BTW, if you have a letter from Brannigan from early 2008 where he talks about what will happen if BN66 becomes law makes for interesting reading if you read it carefully. He said that assuming BN66 becomes law then we'd be liable to be taxed on the Partnerships. Oddly, that must mean that when he wrote the letter which was before it became law that meant we were not liable to tax on the partnership profits without BN66 being law. See where I'm going? HMRC always maintained the Scheme didn't work. Well how can that be true if Brannigan uses a condition of a change in the law as the reason for why we'd become liable?

You might sound I'm being picky but I prefer to use the word "clarify".

That's fine as I guess they will just change the wording retrospectively to clarify its intent. Hey presto... Abracadabra...

[Ninja]

Putting together a time-line that we can use to tell a story, how is this for a start, I would like to highlight facts that indicate misleading of parliament and other relevant info - Can we flesh this out a little?

Nice one!

[Tax_shouldnt_be_taxing]

That's fine as I guess they will just change the wording retrospectively to clarify its intent. Hey presto... Abracadabra...

They might, but they cannot change Hansard no matter how hard they try even though their justification to Ministers had a good go. I'd love to have been a fly on the wall at 100 Parliament St on 5th November when the bloke who read the fax of the IR Explanatory Notes read possibly for the first time, that there are 2 types of retrospection. The one he probably knew about and the one actually used. Fair play though, I doubt Jesus could have been as convincing turning water into wine.

I can hear it now (allegedly):

"**** me!, There's two of these ba*tards! Only 4 days ago we were having a right old laugh about how we could use some 20 year old law to tax this lot with retrospection. What a wheeze. But sh*te alive, we've got retro twins and the one we need is in a coma and the one running around legally stops anyone being taxed. **** me swinging. This will need a miracle. But I can't use the word 'miracle' to describe what we do. Best give the coma twin a better name. I know, Bed Napping 66 or BN66 for short..."

[smalldog]

They might, but they cannot change Hansard no matter how hard they try even though their justification to Ministers had a good go. I'd love to have been a fly on the wall at 100 Parliament St on 5th November when the bloke who read the fax of the IR Explanatory Notes read possibly for the first time, that there are 2 types of retrospection. The one he probably knew about and the one actually used. Fair play though, I doubt Jesus could have been as convincing turning water into wine.

I can hear it now (allegedly):

"**** me!, There's two of these ba*tards! Only 4 days ago we were having a right old laugh about how we could use some 20 year old law to tax this lot with retrospection. What a wheeze. But sh*te alive, we've got retro twins and the one we need is in a coma and the one running around legally stops anyone being taxed. **** me swinging. This will need a miracle. But I can't use the word 'miracle' to describe what we do. Best give the coma twin a better name. I know, Bed Napping 66 or BN66 for short..."

Tsbt please please please take the stand at the tribunal! I feel you have so many rebuttals, insight, reasoned argument and research., I guess for obvious reasons demonstrated recently we don't know mp's strategy as its too risky to divulge with the snakes in the grass, but I for one in the words of Leah feel "help me tsbt, your my only hope!"

[Guttersnipe]

Contacted MP's office (Greg Clark), letter sent to Mr Gauke on 8th. Response expected within next one to two weeks (based on experience rather than anything else).

[lucozade]

brown envelope received

Got my brown envelope detailing that "the responsibility for the enquiries" has now passed to someone in Bournemouth to deal with it.

[DonkeyRhubarb]

Silence from Montpelier

It doesn't mean nothing is happening or they are about to throw in the towel.

There is a lot going on behind the scenes. All the parties involved are now in talks.

Please continue to be patient.

Good things...