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Recent content by webberg
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Response and farewell
I am aware of much adverse criticism here and other social media recently, usually based on inaccurate assumptions and/or driven by unknown motivations. Quite why WTT Big Group is expected to reveal, in public, details of its strategy when others have not, leads me to question why those...- webberg
- Thread
- Replies: 7
- Forum: HMRC Scheme Enquiries
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Hoey - Court of Appeal legal fees
You are correct that it's not my money and without a mandate from my clients, I cannot commit. I have no issues with the lawyers. Some of the thoughts expressed above we have discussed with our own legal team in the past and they take a different view. That legal team is presently unavailable...- webberg
- Post #21
- Forum: HMRC Scheme Enquiries
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Protected Years
If it's a check on a company return, it should say section 12 TMA (from memory - I'm not near my text books). If it does, then there is an open enquiry. Reg 80 is a PAYE assessment. Section 8 in this context means perhaps an NIC advice? Section 9 - not sure - but 9A is a personal enquiry.- webberg
- Post #2
- Forum: HMRC Scheme Enquiries
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Things about to get very serious and much more real? / Felicitas Letters
To be fair, where we advised Felicitas of our involvement in an individual's situation, only one or two SDs. Where we have taken on clients after the last update of authorities to Felicitas, they have had SDs. Clearly cannot say what others experience is.- webberg
- Post #342
- Forum: HMRC Scheme Enquiries
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Edge EBT thread
I suggest you ask Edge and they will share their indemnity with you.- webberg
- Post #1,946
- Forum: HMRC Scheme Enquiries
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Things about to get very serious and much more real? / Felicitas Letters
To be very clear. WTT is quoted in the article tagged but the comment/quote above is NOT one that we made. For the record, we have no information as to Mr Emblin's past or present situation and no reason to think that the loans in point (acquired from Pinotage in the BVI) are part of whatever...- webberg
- Post #313
- Forum: HMRC Scheme Enquiries
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Things about to get very serious and much more real? / Felicitas Letters
I note the posts (#287/291) from eek above. I confess I was unaware of that fact but thank the mods for their diligence and action. WTT has a substantial group of clients who are involved in this. Early joining members of the group have not had SDs. For a small number who have had SD’s and...- webberg
- Post #302
- Forum: HMRC Scheme Enquiries
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Loan Demand what can I do to pre-empt
That is dangerous thinking. If it is dangerous thinking powered by knowledge, professional expertise or personal experience, then I think you owe it to those reading these threads to explain your background in a verifiable way. If you are expressing a hope based on a logical thinking process...- webberg
- Post #14
- Forum: HMRC Scheme Enquiries
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New settlement terms
Disguised remuneration settlement terms 2020 - GOV.UK Lots of new rules to get heads around here. Interesting (and possibly unlawful) twist here is that if the loan charge is paid AND the income from the DR scheme was less than £75k pa, then HMRC "will not collect" any further "tax" (almost...- webberg
- Thread
- Replies: 52
- Forum: HMRC Scheme Enquiries
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Surefield, White Collar Financial and DOTAS
Revenue & Customs v White Collar Financial Ltd (DOTAS - Application for order that certain arrangements are notifiable) [2020] UKFTT 459 (TC) (16 March 2020) HMRC applied to the Tribunal for a decision that the arrangements used in the Surefield iteration of the White Collar family of schemes...- webberg
- Thread
- Replies: 0
- Forum: HMRC Scheme Enquiries
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Loan Demand what can I do to pre-empt
I'm afraid they are not. Not on paper or otherwise. Take heed of the above and if you get a demand for the loan go and get some advice.- webberg
- Post #10
- Forum: HMRC Scheme Enquiries
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Things about to get very serious and much more real? / Felicitas Letters
There are some points above that I have some thoughts on. First, regardless of history, real or imaging connections between original promoters and present active parties, what you think a Court may decide or take into account, ignoring the official statutory demands is very definitely not a...- webberg
- Post #264
- Forum: HMRC Scheme Enquiries
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GAAR Pooling notices - Remuneration Trusts
No - and I'm not expecting to given the fact that the rules were not around pre 2013.- webberg
- Post #18
- Forum: HMRC Scheme Enquiries
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Loans being demanded - a summary
UK Regulation of loans exists in the main to protect the borrower. Therefore the lender has to consider whether the loan will be repaid, affordability, credit worthiness of the borrower, use of the loan - normally limited, security if required, interest rate (which will usually reflect the risk...- webberg
- Post #127
- Forum: HMRC Scheme Enquiries
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Things about to get very serious and much more real? / Felicitas Letters
YOU - not somebody else - YOU need to take steps to protect yourself. That might be appointing and paying a professional, it might be reading up and using online resources to defend yourself. Do NOT however assume that the magic contracting fairy will whisper in the Judges' ears that the loans...- webberg
- Post #252
- Forum: HMRC Scheme Enquiries
