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

[convict]

For people who used The "Talent Resource Management" scheme and have either recently received the class of 08/09 invite or are already under the kosh due to an existing COP8 enquiry. Also for Cherrylon/Trentburg 2009/10 and 2010/11 tickets

Edit:For group representation queries ping me an email [email protected] (this goes for anyone else on TRM/Cherrylon/Trentburg too)

I'm getting quite a few emails. If you want to speed things up when you email me, include some sort of scheme membership proof.

[doncrolleone]

So has everyone sent their letters of disagreement?

[convict]

So has everyone sent their letters of disagreement?

I haven't actually had mine yet. I'm sure it's coming as others at my work have had theirs. Those that I know about have had the standard response from Tax Talk UK and have sent back the three-liner. If/when mine turns up I'll do the same.

I've been checking my SA online account and have not had anything show up there yet. I'm guessing it will appear there first.

[convict]

letter template

Letter template:
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I wish to appeal against the 2008/09 Assessment recently issued.

I disagree that the amount assessed constitutes taxable income and I do not agree the figure issued.

I wish to apply for a full postponement of the tax demanded pending further clarification.
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[richt5a]

I'm a TRM'er

Received the 08/09 letter and Special Civil Investigations letters previously for prior years.

Engaged Gilberts Tax a long time ago.

Still sitting waiting/fighting it out.

[Michael J Perry FCA]

HMRC and Talent Resource Management Limited

For a number of years, I have been dealing with HMRC investigations for contractors who were employed by Talent and have more than 30 ongoing cases.

Talent now operate as Raingold or Futurelink and have set-up a new company to provide tax advice although they do not seem to know very much about Talent as it was before their time.

As Talent was not an EBT scheme (and changed in November 2007 from dividends to loans), it presents a particular challenge for HMRC.

Last year, I was in discussions with HMRC Special Investigations Office about a possible voluntary settlement opportunity for ex-employees but no further progress has been made. A test case could be heard late this year or 2014.

HMRC are likely to attack the scheme under S739 ICTA 1988.

I am in contact with the liquidator of Talent and believe that HMRC now have details of all employees. They are currently in the process of looking at those they missed before (in particular those who joined after 5 April 2007).

I act for many clients that went on to Cherrylon Marketing Limited from 1 April 2009 up to December 2010 (in some cases) and some of those have a further investigation into that employment.

At the same time, some of the ex-Talent people have HMRC enquiries for Sanzar, Darwinpay, AM Limited, etc where they went after Talent although others have heard nothing.

This is a complex area of tax practice but I would be pleased to help out if I can on the forum.

[Andy123]

Gilbert's?

Engaged Gilberts Tax a long time ago.

Still sitting waiting/fighting it out.

I have heard the name Gilbert's on a number of occasions regarding g TRM clients.

Are they any good and what have they achieved for you since you engaged them? I.e. why are you still waiting, have Gilbert's not resolved this with HMRC for you?

I am enquiring with a view to engage someone but not decided yet so any advice on Gilbert's would be appreciated.

P.s. when you look up their address on Google maps, it comes up with a house on a lane in Leeds!

[Michael J Perry FCA]

Appeal letter

It was impossible to guage how much would be written about a simple appeal application.

I have provided over 30 templates to contractors and it would have been less time consuming just to post the suggested reply to HMRC on the forum. However, there was an issue about non-disclosure and professional liability.

I have taken legal advice on this matter and now produce my SUGGESTED reply to HMRC on the understanding that it may not suit all cases and that I accept no financial or professional responsibility for reliance placed on it.

I WILL NOT ENTER INTO ANY DISCUSSION ABOUT THE SUGGESTED LETTER ON THE FORUM.

Assessments are still being issued by HMRC and the latest one I have seen was dated 20 February.

Here is the text of the reply:

YOUR ADDRESS

Date:
Your ref:
NI number:

HM Revenue & Customs
Local Compliance
Personal & CGT Compliance
Chailey House
Cardington Road
Bedford MK42 0YS

For the attention of Miss L J Stopp

Dear Madam,

YOUR NAME

I acknowledge receipt of your letter dated xx February 2013, a notice of assessment and tax calculation for 2008/09.

Please take this letter as my formal notice of appeal against the assessment.

I apply to postpone the further tax charged of £xxxxx on the ground that no additional taxable income has been agreed.

Kindly acknowledge receipt.

Yours faithfully,



………………………………….
(Signature)
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[trickytax]

Another one here, with a letter to appeal.

Does anyone know if the TRM scheme was one known to the HMRC via DOTAS, and was issued with a reference number?

[porrker]

Another one here, with a letter to appeal.

Does anyone know if the TRM scheme was one known to the HMRC via DOTAS, and was issued with a reference number?

Yes it was registered with a DOTAS number. All the schemes users currently being investigated where using schemes with a DOTAS number.