Jon Preshaw TaxJan 142 minHMRC interest and claims to mitigateIt is well known that HMRC take a hard line on the imposition of interest. Many advisers will have heard HMRC explain that the impositio...
Jon Preshaw TaxSep 4, 20201 minGAAR Panel Ruling– can we get rid of Part 7A now (please)? This GAAR panel ruling can’t have been a surprise to anyone. However, I can’t really see any basis on which the transactions could realis...
Jon Preshaw TaxAug 20, 20202 minTribunal criticises HMRC - Is there a reasonable excuse?Two recent cases decided last month, Belloul [2020] UKFTT 312 (TC) and Jacques [2020] UKFTT 311 (TC) contain some really helpful material...
Jon Preshaw TaxAug 14, 20203 minLoan charge guidance – the fog clears (a bit) HMRC have now published guidance on the implications of the Finance Act 2020 changes for ongoing disputes and settlement discussions. As...
Jon Preshaw TaxJun 17, 20205 minHMRC coming out of lockdown - 6 things to look out for Now that HMRC are recommencing compliance activity, there are six key issues which I think they’ll be focussing on over the coming months...
Jon Preshaw TaxMay 29, 20203 minDisguised Remuneration Loan Charge - is it time to act? HMRC’s 'pause' on compliance activity now appears to have ceased. One of the consequence of this is that a number of my clients have rece...
Jon Preshaw TaxMay 12, 20205 minBella Figura, advice and carelessnessEstablishing reasonable excuse and reasonable care in cases where clients have taken advice can be tricky and HMRC can be resistant. The...
Jon Preshaw TaxMar 24, 20203 minLoan charge draft legislation and guidance The draft legislation and some associated guidance following the Morse report were published as part of the budget package. The guidance ...
Jon Preshaw TaxMay 21, 20192 minConfusion continues on loan charge changes Confusion continues on loan charge changes A high degree of uncertainty remains for Individuals who have received loans from EBT’s despit...
Jon Preshaw TaxMay 21, 20192 minOffshore Enabler Penalties Offshore Enabler Penalties Penalties for enablers of offshore non-compliance introduced in Finance Act 2016 have now been effective for m...
Jon Preshaw TaxMay 21, 20192 minHMRC and Discovery Assessments HMRC’s power to raise discovery assessments continues to be the subject of litigation on a number of fronts. Most recently, both the cour...
Jon Preshaw TaxApr 2, 20191 minPrevious publicationsPreviously published articles by Jon Preshaw can be viewed in the links below. ‘One minute with... Jon Preshaw’ | Tax Journal 26 Septembe...