Liechtenstein Disclosure Facility

We were approached by an individual who had received correspondence from the Criminal Investigation section of HMRC. We were instructed by solicitors to provide them with financial information so that they could give legal advice. By reconstituting the financial records of the key offshore entity for a twenty year period and by providing explanations to enquiries and attending meetings with HMRC officers both in the UK and outside of the jurisdiction, we satisfied the interest of HMRC Criminal investigation. This work identified issues with the tax affairs of the individual, who was periodically UK resident but foreign domiciled, and the conclusion we reached was to make a submission under the then available Liechtenstein Disclosure Facility. As a result, the taxation affairs of the individual were settled favourably thereby regularising his tax affairs without the need for a full blown tax investigation by HMRC Fraud Investigation Service (then known as Specialist Investigations).

HMRC In Depth Tax Investigation

Representing an individual and his company under tax investigation for alleged concealment of business revenues and other tax irregularities. Settling the investigation on behalf of the client and satisfying the HMRC Specialist Investigations experienced investigator through a comprehensive analysis of private bank accounts that there was no suppression of business revenues.

HMRC Local Tax Enquiry

A service business was subjected to a full books and records inspection for the second time in five years, the first inspection having resulted in no tax increase. The second inspection demanded business and personal records be delivered to HMRC’s offices. HMRC also wanted to meet the business owner.

Our response was to say these demands were disproportionate and went beyond HMRC’s legitimate powers. HMRC did inspect the business records but at our offices. The remainder of the enquiry was conducted by correspondence and no meeting between HMRC and the business owner took place. This second inspection also resulted in no tax increase.

HMRC COP9 Tax Investigation

We were approached by an individual who had received a letter under Code of Practice 9 alleging HMRC had evidence that undisclosed income and capital gains has been omitted from tax returns.

We made immediate contact with HMRC and arranged an initial meeting at which the client attended. By the strategy we adopted at the meeting, the client was not traumatised by the experience and never had to meet the HMRC officers again.

Our report was scoped in conjunction with HMRC, delivered promptly and the matter concluded with reduced penalties for the fullest co-operation and no adverse publicity for the individual or their family.

Statutory Residence Test

Advising a non UK resident individual on how to remain non UK tax resident under the new Statutory Residence Test whilst visiting his family in the UK for most of the summer each year.

Specialist tax advice for offshore trusts

Advising on the UK tax implications of multiple settlements created from the Will of an individual not resident and not domiciled in the UK. Engaging in extensive correspondence with HM Revenue and Customs resulting in the multiple settlements being dis-aggregated for all UK tax purposes. Outcome was one of the settlements could be absolutely distributed to the beneficiaries without any income tax or Capital Gains Tax being payable on that event.

Specialist tax advice on domicile of UK resident individual

Advising on the domicile of an individual resident in the UK who was not UK domiciled by virtue of his and his father’s origin. The individual had been born in the UK and spent a large part of his childhood and working life in the UK. By showing his connection to his father’s place of birth, and his father’s involuntary displacement from his place of birth, HMRC accepted he was not domiciled in the UK. As he was then taxable on the remittance basis of assessment, I advised on his remittances to the UK so that his tax liability was calculated correctly.

Efficient audit of group of companies

Undertaking the audit of a group of companies in the leisure sector on an effective basis showing the client how to take in-house work previously undertaken by external advisors thereby saving costs.

Structuring a fast growth business

Bringing together the personal and business interests of an entrepreneur with a fast growth business to create a business structure that works for both the continued growth of the business and its potential sale.

Tax structuring on acquisition of family business

Advising the son on how to structure the acquisition of his parent’s industrial company. Obtaining HM Revenue and Customs approval to put a new holding company over the parent’s company in a share for share exchange with a loan note alternative. The parents exchanged their shares in the industrial company for the loan note alternative, which was repayable over ten years. By the parents selecting the loan note alternative, the son became the majority shareholding in the new structure. The loan note alternative allowed him to pay for his parent’s business over a number of years thereby facilitating their retirement.

Agreeing tax position on disposal of entrepreneurial business

Settling the tax affairs of a group of businessmen who had sold their business prior to my being instructed. Agreeing the Capital Gains Tax liability on proceeds received by both the businessmen and the long standing structures set up for the benefit of their families.

Creating an Excluded Property Settlement

Creating a UK resident family trust for a UK resident foreign domiciled individual to make financial provision for his children as they completed their education and become independent of their parents.

Contentious trusteeship appointment

Appointment as a trustee of a family trust by order of the High Court after beneficiaries lost trust and confidence in my predecessor trustee. Taking steps to stabilise the financial position of the family trust to provide regular income to the principal beneficiaries. Worked with investment managers to develop investment strategy for the family trust. Worked with lawyers to develop estate planning approach for the family. Outcome has been long term financial stability for the beneficiaries.

Complex trust administration

Dealing with all tax aspects for a family with “new money” comprising 20 individuals over three generations. The work included administrating the 15 family trusts including preparing all trust accounts and tax returns and overall wealth statements for each branch of the family.

Complex Disposal for Capital Gains Tax

Providing a financial and taxation analysis for an entrepreneurial family disposing of their shareholding in a family business for £200 million and the Capital Gains Tax deferral claim on the reinvestment of part of the proceeds into the new family business.

Tax advice for a rural landed estate

Acting for a “rural” landed estate in the long standing ownership of a family and their trustees. Tax advice included the sale of land with development potential, Inheritance Tax planning to pass the estate from one generation to the next and advising on conditional exemption for estate duty and Inheritance Tax purposes for nationally important works of art.