HMRC powers and enquiries

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Practice notes
On the face of it, there would appear to be no specific impediment, if there is no reason to suppose that a person is without capacity, in them...
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9th Nov
Practice notes
Offshore income gains (OIGs) are gains realised on the disposal of interests in offshore funds which are either:•non-distributor offshore funds, or...
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9th Nov
Practice notes
The issue of sham is most likely to be raised by the settlor's creditors or former spouse if the settlor is involved in matrimonial proceedings, who...
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9th Nov
Practice notes
A trust is formed either by lifetime gift or on death when a person (the settlor) transfers assets to another person or persons (the trustees) to hold...
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Produced in partnership with Mourant Ozannes and Carey Olsen 12th Jan
Practice notes
When trustees are engaged in trust litigation, issues often arise as to how their litigation costs are to be funded. A Beddoe application is the best...
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Produced in partnership with Kate Davenport QC of Outer Temple Chambers and Adele Isaacs of Bankside Chambers 12th Jan
Practice notes
This Practice Note outlines Bermuda trust law and focuses upon its unique features and recent reforms, such as Bermuda's regime for private trust...
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Produced in partnership with Vanessa Lovell Schrum and Caljonah Smith of Appleby, Bermuda 12th Jan
Practice notes
This Practice Note provides guidance on Cayman Islands STAR trusts. For general information about the Cayman Islands, see Practice Note: Private...
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Produced in partnership with Mourant Ozannes and Carey Olsen 12th Jan
Practice notes
Trust litigation has been classified as being of three types:•a dispute as to the trusts on which trustees hold the subject matter of the settlement•a...
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9th Nov
Practice notes
Where a beneficiary either:•is a minor (ie under the age of 18) and unmarried or•has attained majority or has married under that date but is required...
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9th Nov
Practice notes
Duration of a trustThe duration of an express trust is subject to the restrictions imposed by the rules against remoteness of vesting and against the...
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9th Nov
Practice notes
Duty to distribute to the correct beneficiariesOn the termination of the trust, the trustees are under a duty to distribute the trust assets to the...
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9th Nov
Precedents
This Deed of Appointment is made on [date] by [trustee] of [address] and [trustee] of [address] (the Trustees).Background(A)This Deed is supplemental...
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9th Nov
Precedents
This partial deed of revocation is made on [date] by [donor] of [address].1I granted a Lasting Power of Attorney for [Financial Decisions/Health and...
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9th Nov
Practice notes
Liferent trustsA liferent trust (or trust liferent) is a trust which, when settled, confers a use and income benefit, or both, in the trust property...
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Produced in partnership with Peter Murrin of Turcan Connell 12th Jan
Practice notes
An offshore trust is any non-UK resident trust. The liability of trustees of an offshore trust to UK inheritance tax (IHT) is not dependent on the...
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Produced in partnership with Jenny Wilson-Smith and Emma Haley of Boodle Hatfield 12th Jan
Practice notes
Express creation of trustsA trust is constituted expressly where the owner of property (the truster) transfers property to trustees to hold for...
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Produced in partnership with Yvonne Evans, Law Lecturer, Solicitor (non-practising), TEP, University of Dundee 12th Jan

Most recent HMRC powers and enquiries content

Practice notes
HMRC's powers to check a person's tax position are in Schedule 36 to the Finance Act 2008.The powers enable HMRC to:•obtain documents and information,...
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9th Apr
Practice notes
There are various options open to HMRC when it suspects that tax has not been paid, or has been underpaid. These include:•issuing a determination—this...
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9th Apr
Practice notes
Sometimes HMRC will come to the view that a taxpayer has paid, or been assessed for, too little tax, but will come to this view at a time when it is...
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Produced in partnership with Cathya Djanogly 9th Apr
Practice notes
HMRC can investigate suspected tax-related criminal offences in England and Wales using the powers, and subject to the safeguards, in the Police and...
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9th Apr
Practice notes
HMRC's information powers in Schedule 36 to the Finance Act 2008 (FA 2008) (see Practice Note: HMRC information powers) are supplemented by...
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9th Apr
Practice notes
Direct recovery of tax debts (DRD) refers to HMRC's ability to instruct banks and building societies (ie deposit-takers) to deduct amounts to settle...
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9th Apr
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 introduces a new ‘financial institution notice’ (FIN) that can require financial institutions to provide...
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11th Mar
Practice notes
Civil investigation of tax fraudHMRC’s published policy in respect of tax fraud states that HMRC will seek to use a civil rather than criminal...
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Produced in partnership with Corker Binning 26th Feb
Q&As
Rule 16(1) of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (TP(FTT)(TC)R 2009), SI 2009/273, provides as follows (our...
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29th Nov
Q&As
HMRC can open an enquiry into a tax return by giving notice of an enquiry to the taxpayer (or their agent) within certain time limits (referred to as...
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29th Nov

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