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Recent content by deckster
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No To Retro Tax - Ongoing battle against S58 FA2008
Will be interesting to read this. I never expected MP to support TAA (after all the underlying argument is that the MP scheme was a failure) but I'm struggling to see what the risks are given that MP will have pretty much hit the end of the road if/when the Huitson FTT judgement goes against us.- deckster
- Post #2,027
- Forum: Accounting / Legal
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No To Retro Tax - Ongoing battle against S58 FA2008
I'm with Morlock on this. My sole motivation for joining TAA is to have my day in court and protect as much of my capital as I can. The overall NTRT pot is the appropriate place to look for PR funding or anything else not directly related to TAA. Specifically - * I would not support any use...- deckster
- Post #2,010
- Forum: Accounting / Legal
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No To Retro Tax - Ongoing battle against S58 FA2008
I rather think they do (they are, after all, reading this forum) and we should be under no illusions that they will have been working in the background to counter TAA at the FTT. I know we're all excited - I certainly am - but let's not forget that HMRC are well capable of dirty tricks, and...- deckster
- Post #1,701
- Forum: Accounting / Legal
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No To Retro Tax - Ongoing battle against S58 FA2008
Done, done, done and done. Bring it on :mad- deckster
- Post #1,636
- Forum: Accounting / Legal
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No To Retro Tax - Ongoing battle against S58 FA2008
Going back to this, I (and many others, it seems) agree wholeheartedly. What are our timescales here? I'm mindful that we have said that we want to get our FTT proceedings under way before the Huitson decision comes out, which could be pretty soon as I understand it. Clearly we don't want to...- deckster
- Post #1,364
- Forum: Accounting / Legal
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No To Retro Tax - Ongoing battle against S58 FA2008
The entire point of the APN legislation was to force payment of monies in dispute over to HMRC, and apply penalties in the case that payment wasn't made. Therefore, whilst it's true that the exact situation re: surcharge vs penalty and other details are as yet unclear, it's a reasonable...- deckster
- Post #1,090
- Forum: Accounting / Legal
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No To Retro Tax - Ongoing battle against S58 FA2008
Totally agree. It seems to me that our best (only?) way forward now is to push towards the FTT as soon as possible. Anything else - settlement negotiations, reviews etc. - can happily go on in parallel, but we need the tribunal there to force HMRC to play by the rules and not drag things out...- deckster
- Post #1,055
- Forum: Accounting / Legal
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IR35 and HMRC Scheme Enquiries
Can I just remind everybody that HMRC read every word written on this forum. I'm sure they have looked at this in detail anyway but I for one am very uncomfortable about us discussing any potential weakness in the George argument in open forum. Let's not give them any more help than we need to eh.- deckster
- Post #14
- Forum: Accounting / Legal
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No To Retro Tax - Ongoing battle against S58 FA2008
I too would like to see something from MP on what we can do with APNs - however we shouldn't kid ourselves that HMRC are going to let us suspend payment any longer and specifically not pending the outcome of the FTT. That is precisely what APNs were brought in to prevent!- deckster
- Post #216
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
What makes you say that? It was quite clearly stated that APNs can be (and will be) issued to any DOTAS-registered scheme regardless of tribunal status - and that means us. That was after all the primary purpose of APNs in the first place - to put money in HMRCs hands without having to wait...- deckster
- Post #7,733
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
Frankly anybody who doesn't already have a plan in place for what they will do when this happens needs to have their head looked at - it's not like we'll be able claim that it's a surprise! It's all very nice watching from the sidelines, but the fact remains that regardless of what else is...- deckster
- Post #7,695
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
I think DR is talking about the 'opportunity' to pay in full that HMRC have given to the loan/EBT folks http://forums.contractoruk.com/hmrc-scheme-enquiries/100454-settlement-opportunity.html Nothing to do with us BN66ers.- deckster
- Post #7,605
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
Perhaps the more immediate question is when will we start receiving APNs? Have HMRC released any information about how many have been sent out? I guess there's no way of telling where we are in the list. Do we think HMRC are consciously delaying issuing APNs given a) our history of appealing...- deckster
- Post #7,597
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
The only real answer is 'nobody knows' - however personally I am not pinning much hope on ECHR. They specifically say that retrospective legislation is not contrary to human rights per se, and that member countries have a wide latitude in application of tax law, and so I'm not overly concerned...- deckster
- Post #7,299
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
Yes, it's clear-cut that the scheme was ineffective as that is what the court has ruled. Not retrospective at all. In this case, HMRC decided they had a strong case and so went to court - no need any retrospection here. That's only brought out of the bag when HMRC think they might lose :(- deckster
- Post #5,305
- Forum: Accounting / Legal
