HMRC enquiries for Talent Resource Management (TRM) / Cherrylon / Trentburg Schemes

[DMC777]

HM Revenue & Customs: Settlement opportunity: tax on contractor loans

Here is the website the letter directs you to.

[AngryMan]

Representation?

Who are people using for Raingold/FutureLink?

I've tried Matt Hall but apparently knows nothing of the schemes
Michael Perry wants fortunes
Tax Talk never get back to you and seem just to be advising to settle (perhaps to save their parent company?)

[GOLD1]

I would be happy to join forces for TRM and Cherrylone

[pm84280]

TRM - Insurance??

I got a Dear John letter last week and called HMRC today.

For 2007/08 they don't currently legally have the right (from what I can gather) to collar you for 2007/08 as it's beyond the 6 year rule for a personal tax error.

But, my take is that they are looking to win more cases and have it ruled it was deliberate avoidance and hence move this scheme into the 20 year clawback.

Of course, my main concern is 2007-08.

When I go back through records TRM was charging "Insurance = £11" each month. Now, with them in liquidation and me having nothing but a huge potential tax bill with no other paperwork I assume this means nothing.

Was anyone in TRM and know what the insurance was please?

Thanks

[Krung Thep]

I got a Dear John letter last week and called HMRC today.

For 2007/08 they don't currently legally have the right (from what I can gather) to collar you for 2007/08 as it's beyond the 6 year rule for a personal tax error.

But, my take is that they are looking to win more cases and have it ruled it was deliberate avoidance and hence move this scheme into the 20 year clawback.

Of course, my main concern is 2007-08.

When I go back through records TRM was charging "Insurance = £11" each month. Now, with them in liquidation and me having nothing but a huge potential tax bill with no other paperwork I assume this means nothing.

Was anyone in TRM and know what the insurance was please?

Thanks

2007/08 WAS my main concern until the 6 year rule passed in April this year. What makes you think HMRC are going to implement the 20 year rule for TRM or any other scheme? Do you know something that no-one else does?

[stonehenge]

Michael Perry wants fortunes

I've heard this from a few people who've approached him. Some who've handed over large sums now regret it.

[pm84280]

2007/08 WAS my main concern until the 6 year rule passed in April this year. What makes you think HMRC are going to implement the 20 year rule for TRM or any other scheme? Do you know something that no-one else does?

Well, there in lies the key as far as I can see...

This is just from a few hours of research to arm myself with knowledge.
As I've said, it seems HMRC want to you pretend to be a Turkey and then vote for Christmas which is why they are sending requests for 2008-2009 but they did not for 2007-2008 or prior (and they admitted to me this morning they had it open but had never sent a request).

They knew what my figure was for 2008-2009 but couldn't tell me for 2007-2008.
Ultimately though, if they win cases can they legally move the goalpost and move this from "Discovery assessment for careless behaviour" (6 years) to "Discovery assessment for deliberate behaviour" which carries 20 years.

Even if they did I guess the question would then go to British or European law to prove they could do this but again, I guess only a lawyer or seriously qualified accountant could answer that question.

Anyone qualified to answer that?

[AngryMan]

...if, as per Rangers, you can prove the loan was repayable.

Proof would come if you started to pay it back, no?

[malvolio]

Well, there in lies the key as far as I can see...

This is just from a few hours of research to arm myself with knowledge.
As I've said, it seems HMRC want to you pretend to be a Turkey and then vote for Christmas which is why they are sending requests for 2008-2009 but they did not for 2007-2008 or prior (and they admitted to me this morning they had it open but had never sent a request).

They knew what my figure was for 2008-2009 but couldn't tell me for 2007-2008.
Ultimately though, if they win cases can they legally move the goalpost and move this from "Discovery assessment for careless behaviour" (6 years) to "Discovery assessment for deliberate behaviour" which carries 20 years.

Even if they did I guess the question would then go to British or European law to prove they could do this but again, I guess only a lawyer or seriously qualified accountant could answer that question.

Anyone qualified to answer that?

Rather depends - it's a subjective assessment based on what you've told them and what other people, such as the scheme providers, have told them. One an enquiry has been opened, they can go back from that point

And at the end of the day it's up to you to ensure you report stuff accurately; you're allowed to make a mistake - which is the 6 year trigger - but if it appears you are hiding something, even by omission since you're only doing what your advisors have told you to do, and only for one tax year, then that's the open door option for HMRC. And to be honest that is the real bummer here; a lot of people are in this mess for all the wrong reasons.

And it's not 20 years, that's just the usual limit. In reality it's open ended.

[DMC777]

Well, there in lies the key as far as I can see...

This is just from a few hours of research to arm myself with knowledge.
As I've said, it seems HMRC want to you pretend to be a Turkey and then vote for Christmas which is why they are sending requests for 2008-2009 but they did not for 2007-2008 or prior (and they admitted to me this morning they had it open but had never sent a request).

They knew what my figure was for 2008-2009 but couldn't tell me for 2007-2008.
Ultimately though, if they win cases can they legally move the goalpost and move this from "Discovery assessment for careless behaviour" (6 years) to "Discovery assessment for deliberate behaviour" which carries 20 years.

Even if they did I guess the question would then go to British or European law to prove they could do this but again, I guess only a lawyer or seriously qualified accountant could answer that question.

Anyone qualified to answer that?

This is what a lot of boards are saying, that HRMC will use any data they get for 2007/2008 to invoke the 20 year rule.