HMRC Enquiry letters on Loans from EBT and other schemes

[ireland2013]

Sorry but there is no comparison with BN66.

HMRC never tested the legality of the BN66 double tax scheme in court. That's because they knew they would have lost.

They got Parliament to enact retrospective legislation. The law was changed back to 1987 so that the scheme was never legal.

thanks for the info - I understand what you are saying regards BN66

[Michael J Perry FCA]

London Seminar on HMRC and EBT Schemes

The poll for attendance at the seminar to be held in London on 6 or 7 April (TBC) will close on 2 April.

Please see the separate thread to register your attendance - EBT Seminar.

About 35 attendees so far who you will be able to network with at the meeting.

A big thank you to ''Convict'' who is arranging the seminar and to CONTRACTOR UK for letting us organise this event.

[kjar]

Appeal Letter

Hi Michael
Could you provide me with a way of contacting you to discuss getting a copy of your recommended appeal letter.

I do not seem to have the privelages to inbox you, unless I am not loking in the correct place. Thanks

I have already offered to supply the correct form of appeal letter to anyone that wants it free of charge, if they only wish to deal with the immediate problem and then decide what to do later.

As you would expect, I need to make reasonably sure that the appeal letter is correct for your circumstances and obtain a simple disclosure undertaking.

For anyone that does not know already, I am a Chartered Accountant tax consultant specialising in HMRC Code of Practice 8 enquiries and Disguised Remuneration schemes. I do not undertake any other type of work.

[kjar]

Upgrade

Hi could you please upgrade my account so I can PM Michael?
Thanks Kindly

Hi Can you please upgrade my account as well as I would like to get in touch with Michael

[Michael J Perry FCA]

Appeal letter

Hi could you please upgrade my account so I can PM Michael?
Thanks Kindly

Please see my post on this thread #351.

[Crofty]

Another HMRC target arrives

Just been reading back over the threads, I've also received a letter from HMRC demanding payment for 08/09, I was with AML and they are still in business so I've already contacted them and they are now handling this on my behalf. Having read about some other people's providers disappearing I feel a little lucky to be with AML although this was purely by chance at the time. I only used AML during an interim period while I was contracting but my position is very clear on this. What HMRC are attempting to do is adjust the law to suit their own purposes. Be under no illusion here, as I understand it the EBT is a perfectly legal construct and if administered correctly does not breach any tax laws, just because HMRC want to interpret the law in a particular way it doesn't mean that they will succeed.

Furthermore, if the scheme provider registered the scheme and received a registration number and you in turn notified the tax authorities that you used this scheme when submitting your tax return then what exactly have HMRC discovered? If you filled out the scheme number on your tax return and it went through at the time them it is reasonable that HMRC will have read your tax return in full and not skipped parts of it!!

It is also reasonable to expect that HMRC understood your use of the scheme as it was HMRC that issued the scheme registration number.

In my opinion HMRC have messed up with the discovery, this is where the administration of the scheme is important provided that the scheme provider, in my case AML can show that they have administered it in line with what was registered with HMRC then it is for HMRC to prove otherwise for their discovery to be valid. If AML have operated the scheme in line with what was laid out to HMRC and individuals that made use of the scheme have notified HMRC of the use then there simply is nothing to discover and so any claim is time barred.

If HMRC can show that the scheme was not administered properly then they can claim a discovery and they can then attack the validity of the scheme itself and this is a whole different argument.

I have appointed AML to act on my behalf even though I am no longer associated with them. They seem very helpful and I await HMRC's next move.

Crofty.

[Michael J Perry FCA]

London Seminar on HMRC and EBT Schemes

The poll for attendance at the London Seminar on Saturday 6 April will be closing on Tuesday morning and we need to know numbers by then.

Over 50 people signed up already!

See the thread at London EBT Seminar to find out how to register.

[convict]

If any of you guys are intending to attend the seminar on Saturday, please see posts 24 onwards in the thread below. You should secure your seat asap to avoid disappointment - space is limited

http://forums.contractoruk.com/hmrc-...ml#post1720974

[Michael J Perry FCA]

London Seminar on HMRC and EBT Schemes

if any of you guys are intending to attend the seminar on saturday, please see posts 24 onwards in the thread below. You should secure your seat asap to avoid disappointment - space is limited

http://forums.contractoruk.com/hmrc-...ml#post1720974

This afternoon is the final opportunity to register for tomorrow's seminar which will not be repeated.

If you have received a 2008/09 assessment or a s9a/cop 8 enquiry notice, this is possibly the start of a long and well trodden road and you need to be well informed about how to deal with it.

Hope to meet with you tommorow.

[AthomeinOz]

PM rights.

I'll ask Admin for PM rights for you costo.

Hi Cojak,

Could you organise for PM rights, as I too got the 08/09 letter and need to get in contact with Michael urgently. My 30 days is down to 14 due to snail mail to Oz.