Loan charge guidance – the fog clears (a bit)

Loan charge guidance – the fog clears (a bit)

By Jon Preshaw HMRC have now published guidance on the implications of the Finance Act 2020 changes for ongoing disputes and settlement discussions. As ever, there are a few steps forward and a few steps back. There’s also lots to do before the (now absolutely fixed)...
Bella Figura, advice and carelessness

Bella Figura, advice and carelessness

Establishing reasonable excuse and reasonable care in cases where clients have taken advice can be tricky and HMRC can be resistant. The recent decision of the Upper Tribunal in Bella Figura should help. HMRC officers seem increasingly reluctant to accept that clients...