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[jamesbrown]

It's just another example of over-complicating rather than simplifying. For example, consider people that have PAYE income that fluctuates or is much smaller than an amount that could be collected that way. Isn't that why you can only currently do this if the amount is less than £3k (i.e., opt for...

[jamesbrown]

Largely unrelated (focused on LLPs, but pushing in the same general direction w/r to more people on the payroll), but this one just finished in the SC, around 5 years after the FTT in 2021, so 2031 is not ridiculous:

https://www.cityam.com/hedge-fund-ru...-financier-los...

[jamesbrown]

The "cash-like" definition definitely covers money market funds, but only 100% investments in them So, as I understand it, you could have 99.9% in a MMF and 0.1% in, say, gold, and you'd be fine. This (among other reasons) is why the industry is pointing and laughing. It is such a classic...

[jamesbrown]

This is all pre-emptive "big brain" because the £12k limit and associated tax on cash-like investments doesn't kick in until next year. There is no existing loophole, other than low-risk investments currently being available within S&S ISA wrappers. They were simply trying to get more...

[jamesbrown]

Handy Kafkaesque word map:

• Simplification: easier for us to collect tax from baddies*
• Fairness: more tax from baddies*

*you...

[jamesbrown]

Exactly this. It really isn't much different than any other legal hearing in that regard. It is a structural artifact of being an adversarial legal system where you literally advocate, especially in your closing statement, you don't provide a balanced view. If you've never witnessed that before, I can...

[jamesbrown]

My reading is that yup29 paid the full amount of outstanding tax under the deemed payment calculation (plus the separate fine to CH for the unrelated failures) and HMRC considered that to be "good faith" () and "allowed" the statutorily required offsets to be applied against...

[jamesbrown]

Denying, they simply cannot do for a timely request because that is explicitly legislated against (specifically, w/r to taxes on distributions like dividends in Chapter 9, but there is similar/general legislation for other taxes, notably CT). Delay (and even lies about denying) is a different matter,...

[jamesbrown]

Yes, it is/was relatively common for an accountant to set up the company, just not great. However, the major red flag was the tax loss insurance due to the way the legislation is worded, but this definitely isn't the same risk with regular business insurance - it isn't a great look, tbh, but not an...

[jamesbrown]

There are a couple of red flags there, tbh. Accountant creating the company. Accountant providing tax loss insurance. The latter is a big red flag given the wording of ITEPA Ch. 9:



I don't think either of CK or Boox did that. If Crunch are or were doing that, and you have...

[jamesbrown]

I understand the concern, but you shouldn't get overly worried about this. HMRC is taking its usual hardline position, which is theatre. Even if the case is lost (still unlikely in my view) and there is an eventual tax debt, it is within the remit of a tribunal judge to issue a binding direction about...

[jamesbrown]

I think you are severely overestimating Milan's abilities. I mean, he purchased a Porsche that isn't a 911....

[jamesbrown]

+1 for no accountants (well, no accountants plus some personal competence), but also +1 for not getting too excited about the summing up from HMRC barristers, it is a completely unconstrained sales pitch. As you say, the implications of a resounding loss would be severe and broad, far beyond the scope...

[jamesbrown]

You need to retain it as long as the company is open, minimally. Furthermore, depending on your risk tolerance and client base, you may want to look into run-off insurance, even once the company is closed, because the liability does not simply end with closure (and closure isn't necessarily permane...

[jamesbrown]

Admin redeployed the CUK data protection team to answer FAQs about social care....

[jamesbrown]

( The youngest member of the forum is 43. )...

[jamesbrown]

Or air conditioning, like civilised people...

[jamesbrown]

Not to re-litigate this for the millionth time, but the problem with the Christianyou case wasn't the direct analogy to contractors operating with accountants at all. Christianyou was always a totally different situation and unarguable. The problem for contractors operating with accountants is what...

[jamesbrown]

TBF, the Boox advertising was always unanswerable, so no surprise they are probing this. It was always the equivalent of a "kick me" sign....

[jamesbrown]

It's public, so you can attend in person (very few seats) or online. That said, it will be too late now for the current hearing. In future, you can e-mail taxappeals@justice.gov.uk in advance with your details and the case details and request a link to the online meeting (the Boox case number is TC/2025/00190,...