Harriet Brown

Barrister and Jersey Advocate, Old Square Tax Chambers

Harriet is qualified to practice in England and Wales and Jersey. She has rights of audience before all courts in both jurisdictions. Harriet advises taxpayers in relation to UK tax matters. She advises on all direct tax matters for private and corporate clients as well as in the context of trusts and estates, and on indirect tax matters. In addition to advising extensively on traditional private client matters, Harriet has a particular interest in international matters such as double tax treaties, TIEAs, disclosure facilities and conflict of laws issues arising in a tax context. Harriet also has extensive experience of resolving disputes with HMRC in both direct and indirect tax matters. Her approach is always to give detailed and practical advice from the initial enquiry through to any tribunal hearing. She offers a full service, particularly advising on the conduct and settling of tax enquiries, which often results in a favourable conclusion at an early stage. She can advise and act in all forms of alternative dispute resolution with HMRC, as well as in traditional litigation.

Contributed to

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A three storey house is converted into three flats and the flat leases have 65 years left to run. The

Q&A

This Q&A considers whether there are any adverse capital gains tax consequences to a management company or the leaseholders when a freehold was purchased by a management company and leaseholders are the shareholders and directors of the management company.

Property

What will be the Capital Gains Tax (CGT) liability where a wife has died leaving a Nil Rate Band Trust in

Q&A

This Q&A explores the Capital Gains Tax liability where a wife has left a nil rate band in her Will and the trustees wish to make an appointment out of the trust to the surviving husband, three years after her death.

Private Client

Where an estate is insolvent, would bank accounts where the deceased is overdrawn, credit cards where

Q&A

This Q&A considers whether bank accounts where the deceased is overdrawn, credit cards where there are balances to pay, and income tax outstanding to HMRC would be considered ordinary debts or preferential debts where an estate is insolvent, and the how interest should be treated surround this.

Restructuring & Insolvency

X settled an accumulation and maintenance trust prior to 2006. No changes have been made to the terms of

Q&A

This Q&A considers the application of IHTA 1984, s 71 to pre-2006 accumulation and maintenance trusts.

Private Client