Shelford & anr v HMRC [2020] UKFTT 0053 (TC)

WTLR Issue: Summer 2020

John Selwyn Herbert (Mr Herbert), a widower with three children, owned and lived in the freehold house, 12 Hammersmith Terrace, London (the house). In 2001, Mr Herbert obtained inheritance tax advice from Stevens & Bolton to implement what was described as the ‘home loan scheme’ and he asked the second appellant, Mr Shelford, who was a solicitor and partner in Edwin Coe, to act as a trustee of the Herbert Life Interest Settlement (the settlement)...

Banks v HMRC [2018] UKFTT 617 (TC)

WTLR Issue: Spring 2020

The appellant taxpayer, Arron Banks, appealed against a notice of determination issued by HMRC. This notice assessed Mr Banks as owing inheritance tax of £162,945.34 on donations of £976,781.38 that he and companies that he controlled made to the UK Independence Party (UKIP) between October 2014 and March 2015 (the donations)...

Charnley v HMRC [2019] UKFTT 0650 (TC)

WTLR Issue: Spring 2020

Mr Gill’s estate included the house in which he lived, a brick barn and outbuildings and 21 acres of permanent pasture. During the relevant period Mr Gill did not own any livestock. He allowed farmers to graze their livestock on his agricultural land under annual grazing licences...

Kersner v HMRC [2019] UKFTT 221 (TC)

WTLR Issue: Autumn 2019 #176

On an appeal against HMRC’s determination of liability to inheritance tax the appellant made a number of applications in the First-Tier Tribunal (Tax Chamber), including an application to opt out of the complex track costs regime, and for disclosure of documents alleged to be relevant to the HMRC’s assessment that the appellant had not been domiciled in the UK, but in Israel, when shares had been transferred to her by her husband...

Hogarth v HMRC [2018] UKFTT 0595 (TC)

WTLR Issue: Spring 2019 #174

The appellants were trustees of a life interest trust, the income of which was mandated to the life tenant and passed directly to him. HMRC served a notice under s8A of the Taxes Management Act 1970 to file an income tax return on the trustees...

Rialas v HMRC [2019] UKFTT 520 (TC)

WTLR Issue: Winter 2019

During the relevant tax years, R was resident and ordinarily resident, but not domiciled, in the United Kingdom. He was a Cypriot national. He held 50% of the issued shares of ACM, a company incorporated in England and Wales. R worked full time in ACM, which carried on a successful business as a fund manager...

Skinner v HMRC [2019] UKFTT 0516 (TC)

WTLR Issue: Winter 2019

On 1 December 2015 three settlements (“the Skinner Settlements”) disposed of 55,000 ordinary shares (“the Shares”) in a company (“the Company”) at a gain. Under each Skinner Settlement a member of the Skinner family had been given an interest in possession in the whole of the settled property on 30 July 2015...

Ross v HMRC [2017] UKFTT 507 (TC)

WTLR Issue: Winter 2018 #170

Mrs Ross originally owned a hotel called the Port Gaverne Inn in Cornwall and later acquired eight holiday cottages across the road called the Green Door Cottages. When she was no longer fit enough to run the business, the hotel was sold though its new owner agreed to provide services to guests renting out the cottages...