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Recent content by Emigre
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
Well done, and thanks for the feedback!- Emigre
- Post #3,113
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
WHS. It does take guts but at the end of the day MPs are no different to anyone else - they have a job to do - which above all else is to represent their constituents. In my experience, if someone has taken the trouble to take time off work and to meet with them they will want to understand...- Emigre
- Post #3,096
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
The aim of the toolkit is to empower you to be able to answer questions that may be asked of you by your MP in a positive way. Of course you are right that it would be difficult for you to present everything contained in the presentation. No one expects that - it is more about getting a...- Emigre
- Post #3,087
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
The next toolkit will be with you shortly.- Emigre
- Post #3,077
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
Nice of you to stop by DaveB...but then I guess we are slipping into code speak.- Emigre
- Post #3,064
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
Or similar words by Lord Tomlin... “Every man is entitled if he can to arrange his affairs so that the tax attaching under the appropriate Acts is less than it otherwise would be. If he succeeds in ordering them so as to secure that result, then, however unappreciative the Commissioners of...- Emigre
- Post #3,058
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
Lisa, Having read the disclosure facility agreement am I right in thinking that it is targeted at hitherto undeclared assets (and therefore income) in IOM? If so, isn't that a very different thing to our situation where we obtained a DOTAS reference (potentially even where one was not...- Emigre
- Post #3,056
- Forum: Accounting / Legal
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HMRC Enquiry letters on Loans from EBT and other schemes
A generous offer. Reputation point given.- Emigre
- Post #88
- Forum: HMRC Scheme Enquiries
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
I don't know the answer to your question. I like your logic though. There are two different things here. The FTT is a tax tribunal and does not set precedent. Once the appeal process within the tax tribunal system has been exhausted cases can move to the High Court and beyond where precedent is...- Emigre
- Post #3,036
- Forum: Accounting / Legal
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HMRC Enquiry letters on Loans from EBT and other schemes
This and the other related thread are a group. If you want to take it further than that I suggest that you read up on the S58 threads and the NTRT thread and how that came into existence. There is a difference here. The S58 thread came into being as a direct result of unannounced retrospective...- Emigre
- Post #70
- Forum: HMRC Scheme Enquiries
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
Regardless of anything that we achieve, there will be nothing in the Budget speech itself. As always with these things the devil will be in the detail. We are of course pushing hard to see if we can get an angel put in the detail this time but as you know Gauke is not playing ball and prefers...- Emigre
- Post #3,034
- Forum: Accounting / Legal
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
As a said, there is more in the newsletter about this. We have provided information to his Counsel. It is an individual case with individual circumstances and whilst it may "colour" the FTT it is certainly not binding on us. Any one of us would still be able to take our own cases. Further...- Emigre
- Post #3,033
- Forum: Accounting / Legal
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Loans from EBTs and other Trusts
If your arrangement received a DOTAS reference then that reference should have been included on your SAR. You should find it there.- Emigre
- Post #621
- Forum: Accounting / Legal
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HMRC Enquiry letters on Loans from EBT and other schemes
I am not familiar with the terms of the TRM or Edge arrangements. Were you employees of a business/partnership or self employed contractors? If you were self-employed it is less likely that a loan from a trust could be deemed to be employment income. As has already been posted, HMRC have not...- Emigre
- Post #32
- Forum: HMRC Scheme Enquiries
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No To Retro Tax – Campaign Against Section 58 Finance Act 2008
We are aware of an FTT for another (non-MontP) person trying to be scheduled for this year. The newsletter gives more info on that.- Emigre
- Post #3,028
- Forum: Accounting / Legal
