AM Limited COP8 HMRC Investigation Letter..

[webberg]

Site still not accepting new registrations.

That's because you're going to WTT Big Group and not WTT Consulting.

Big group is closed until late April probably.

WTT Consulting would be happy to help so call us.

[WalterWhite]

At the most basic level, so that not all eggs are in one basket?

I suppose.

My understanding is that Big Group are looking for a favourable settlement figure though whereas AML are defending the scheme (I may be wrong) so wouldn't it be a conflict of interest to have both acting on your behalf?

Unless of course the poster just wants advice from BG

[regron]

I suppose.

My understanding is that Big Group are looking for a favourable settlement figure though whereas AML are defending the scheme (I may be wrong) so wouldn't it be a conflict of interest to have both acting on your behalf?

Unless of course the poster just wants advice from BG

Correct, but defending the scheme is fruitless for the clients now the 2019 charge is on the horizon. Winning that will only benefit AML from the new legislation around punishing the provider if they lose in court. The tide has turned...rapidly !

[jes107]

12/13 Assessment

I have a few years open for investigation. Received the first notice of assessment from HMRC and AML have appealed this on my behalf. Happy that AML are doing this but is it just a case of delaying the inevitable come 2019? I guess it will make it a lot easier to go bankrupt if I just get the one bill meaning I can try lead a normalish life til then. I am waiting for big group to open as I want to find out what others are doing with regards to planning for bankruptcy.

[regron]

I have a few years open for investigation. Received the first notice of assessment from HMRC and AML have appealed this on my behalf. Happy that AML are doing this but is it just a case of delaying the inevitable come 2019? I guess it will make it a lot easier to go bankrupt if I just get the one bill meaning I can try lead a normalish life til then. I am waiting for big group to open as I want to find out what others are doing with regards to planning for bankruptcy.

If I am reading this correctly then no it won't, that is what the 2019 rule is all about, catch all. So you will have to declare ALL years you took loans via schemes on your self assessment, regardless of how many DA's or enquiry letters you receive between now and then. Failure to do so = Evasion ! Not doing this to scare you, but to ensure you understand what the 2019 proposal is all about. Start preparing now. Although Big Group itself is currently closed, WTT consulting isn't, so maybe an idea to give them, or any other professional advisor a call to get advice.

[WTFH]

Unconfirmed information that I've just heard is that AM Limited have lost the first part of their fight with HMRC and that closure notices are being sent out over the next few weeks. They are saying that they will be appealing against all cases en masse.

[DotasScandal]

Unconfirmed information that I've just heard is that AM Limited have lost the first part of their fight with HMRC and that closure notices are being sent out over the next few weeks. They are saying that they will be appealing against all cases en masse.

Not familiar with the AML game plan, but aren't closure notices a necessary prelude to FTT?

[WalterWhite]

Unconfirmed information that I've just heard is that AM Limited have lost the first part of their fight with HMRC and that closure notices are being sent out over the next few weeks. They are saying that they will be appealing against all cases en masse.

Would there not be a link online to a case of some sort if this were true? Not so much the result but it would be on the listings of a court on the day they were due there?

[difficulttimes]

Not familiar with the AML game plan, but aren't closure notices a necessary prelude to FTT?

Yes that would be correct. Either party needs to ask for closure notices and then it is up to the impartial judiciary to decide if there is any tax owed.

[webberg]

A closure notice is a statement from HMRC saying why they think tax should be charged or relief denied.

You are correct in that is precedes a FTT case as it represents HMRC's position that is subsequently developed and presented by an advocate in Tribunal.

It's also almost unheard of for a decision on such a major case to be made at the hearing or within a few days. The Tribunal on the substantive issue we understand is scheduled for this summer but we are not expecting a decision on it until later this year or early next.

Perhaps we are incorrect in that assumption but given the importance of the positions of the parties here, I would be astounded if this decision was on the substantive issue.

Rather we know that AML has been challenging APNs.

It may well be therefore that the decision here is on APN matters and not the issue of actual liability.

Obviously if the case is reported (not all are), we will know.

Alternatively AML may communicate something to their clients.

Whilst I appreciate that you can't do much with rumours except spread them, given the gravity of this issue and the fact that many AML (and other) arrangement users are already fragile in many ways, it would be sensible to wait for the facts to be reported rather than speculate?