Ownership and tax issues – HMRC guidance on constructive and resulting trusts

Ownership and tax issues – HMRC guidance on constructive and resulting trusts

It is straightforward in most cases to establish an individual’s income entitlement for tax purposes. However, there are exceptions. HM Revenue andCustoms (HMRC) recently issued new guidance in its Trusts Settlements and Estates manual on the concepts of ‘resulting trust’ and ‘constructive trust’ for income tax purposes. These are ‘implied trusts’, which are created by. Read more

Penalties and costs – The taxpayer fights back

Penalties and costs – The taxpayer fights back

Taxpayers have recently been successful in a number of appeals before the tax tribunal on the grounds of ‘reasonable excuse’, mainly in respect of late filing penalties. One such case is highlighted below. In addition, the approach of HM Revenue and Customs (HMRC) in a case involving a discovery assessment was criticised by the tribunal,. Read more

BPro Tax

Tax Online

Online access to Bloomsbury Professional books, looseleafs and journals, across numerous practice areas. Free Trial