BIG GROUP

[ChimpMaster]

Webberg,

you might have answered this already but it's a long thread so I'll ask anyway: what happens when the Big Group case hasn't yet concluded, but the LC kicks in and it's time to submit Tax Returns with LC data on them? And then if Jan 2020 comes around and the case still isn't concluded?

Will participants be advised to pay, or not pay, at that point?

[webberg]

We believe that the loan charge legislation is flawed - an impression strengthened by a discussion with an ex HMRC inspector today - and can be resisted.

We will make a a disclosure because the penalty for not doing so is steep and not to be risked. Whether it is in the format currently offered or is outside the return remains to be determined.

We think however that we can resist any subsequent assessment.

This is NOT a risk free situation but given that we do not expect to have our own litigation progressed enough to have a decision by the end of January 2020, we have developed the plan with our barrister and will be adopting it.

[webberg]

Big Group is not closed

I've had a few messages saying that the sender thinks Big Group is "officially closed".

It is not.

Your options have however shifted since we went over the last tax year end.

Settlement was an option up to 5th April 2019, when you had to have submitted your loan and other details to HMRC.

Submitting details after that time is no guarantee of settlement being achieved.

If you do not settle, than HMRC expect you to be subject to the loan charge which is their view appears to a panacea for all ills and which captures every single arrangement in existence.

This flies in the face of some arrangements being claimed as "loan free", others saying that the letter of the loan charge law is not applicable and others claiming more exotic means of avoiding the charge.

So, no guarantee that the loan charge will apply.

It may even be the case that the efforts of the APPG will see the loan charge consigned to the bin marked "bad ideas" and will be withdrawn. How and when that might happen is unknown.

Whether the loan charge applies or not, the business of agreeing whether there is a charge on the loans - in the year received - goes on.

Our own litigation efforts on this are advancing and dates for initial hearings are imminent. We are aware of others who will be in Tribunal before us.

(We are also aware that some litigations we were told were "pending", some more than 2 years ago, have yet to advance to a hearing date but perhaps there are tactics being applied here?)

It's likely that settlement terms as presently offered will be unavailable now, but other, less favourable terms, may be. It could be that all terms are withdrawn until we all see the results of Tribunal action. We don't know.

In any event, our action continues and new joiners are welcome up to the steps of the Tribunal.

We do not claim a guaranteed success, nor a smooth ride, nor any special ability to resist demand for payment. We do promise a decent idea, backed by a barrister for whatever that is worth and a commitment to see this through.

We have no "skin in the game" in terms of having promoted schemes in the past and therefore no potential for conflict. We have no reason to delay litigation and now that the settlement date has passed, will be doing our best to get before the Tribunal as soon as we can.

So, Big Group is open and you can contact us for a discussion if you wish.

[webberg]

Yesterday we posted to the BG Forum a message to all users of:

Marra - Kirium - Invicta.

These were White Collar offerings from 2006 onwards.

We are looking to accelerate litigation on these schemes and have put out a call for any unseen material to be sent to us in preparation.

We will be following this up with a targeted message tomorrow.

However if neither reach you, please contact us if you used the above.

[Jimmybrown]

We have no reason to delay litigation

With a monthly fee model? Sure!

[webberg]

With a monthly fee model? Sure!

Ah I see. You're suggesting that my only motive should be to keep collecting the fees and stall for as long as possible.

If that were the case, then I would have no staff, no extensions of our work into legal areas, no extensions into working platforms for now and the future, no London offices, no insurance and would keep all communications to a minimum and not have physical and digital seminar/webinar, not spend many hours speaking with the media and MPs and HMRC and not engage with the Tribunal to advance more than the two cases we have going ahead in the next few months.

I would be significantly more wealthy of course if I did all of the above.

I suggest however that some of the clients who have been with us since day 1 (over 4 years ago) would have probably rumbled us and stopped paying (there is no penalty for stopping).

You are of course entitled to your view and to share it.

I suggest however that even a cursory examination of the facts would show that your view is without much substance.

Better still you could call us and we'll happily explain where we spend our clients' fees.

[regron]

Ah I see. You're suggesting that my only motive should be to keep collecting the fees and stall for as long as possible.

If that were the case, then I would have no staff, no extensions of our work into legal areas, no extensions into working platforms for now and the future, no London offices, no insurance and would keep all communications to a minimum and not have physical and digital seminar/webinar, not spend many hours speaking with the media and MPs and HMRC and not engage with the Tribunal to advance more than the two cases we have going ahead in the next few months.

I would be significantly more wealthy of course if I did all of the above.

I suggest however that some of the clients who have been with us since day 1 (over 4 years ago) would have probably rumbled us and stopped paying (there is no penalty for stopping).

You are of course entitled to your view and to share it.

I suggest however that even a cursory examination of the facts would show that your view is without much substance.

Better still you could call us and we'll happily explain where we spend our clients' fees.

I am one of those who have been a member literally, since day one and it’s been worth EVERY penny.

[Jimmybrown]

Ah I see. You're suggesting that my only motive should be to keep collecting the fees and stall for as long as possible.

If that were the case, then I would have no staff, no extensions of our work into legal areas, no extensions into working platforms for now and the future, no London offices, no insurance and would keep all communications to a minimum and not have physical and digital seminar/webinar, not spend many hours speaking with the media and MPs and HMRC and not engage with the Tribunal to advance more than the two cases we have going ahead in the next few months.

I would be significantly more wealthy of course if I did all of the above.

I suggest however that some of the clients who have been with us since day 1 (over 4 years ago) would have probably rumbled us and stopped paying (there is no penalty for stopping).

You are of course entitled to your view and to share it.

I suggest however that even a cursory examination of the facts would show that your view is without much substance.

Better still you could call us and we'll happily explain where we spend our clients' fees.

That's the most pompous thin I've read in quite sometime. King of the Contractors you Webberg!

[piebaps]

There's a separate thread for this kinda stuff jimmy.

[Jimmybrown]

There's a separate thread for this kinda stuff jimmy.

This kinda stuff?

He makes out he's Mr Integrity when he's designed tax products for a living. All those media briefs good for your ego Webberg? You and that clown from Contractor Calculator are sickening.

So tell us, how fairs Big Group? Think you're going to win? you'd better hope so now the LC is in play.