Professional negligence
I was instructed by specialist professional negligence solicitors in respect of a multi-million pound claim by multiple claimants against a 'Big Four' firm for allegedly negligent historic tax planning advice. The robust advice I was able to give on liability and quantum was a major factor in securing a satisfactory out-of-court settlement of the dispute.
CGT losses
In a Capital Gains Tax case involving the meaning of 'negligible value' where seven-figure tax losses were at stake HMRC, having first vigorously resisted the claim on the basis of their established and published practice, backed down on 'internal review' after it had been made crystal clear that we were prepared to pursue the case to a Tribunal hearing.
Taxable benefit
In a case where HMRC asserted that certain expenditure by a company gave rise to very substantial amounts of Income Tax and NIC under the 'benefits in kind' regime, a hearing before the First-tier Tribunal resulted in all matters being resolved in the client's favour.
Fraud investigation service
HMRC challenged a client's tax returns on suspicion of serious tax fraud. Constructive engagement with HMRC's elite Fraud Investigation Service reduced the settlement from the millions initially suggested to just a few thousand pounds - with no penalty payable.
SEIS relief
Did a business of breeding thoroughbred horses potentially qualify for relief under the Seed Enterprise Investment Scheme? HMRC insisted not - until the matter was appealed to the First-tier Tribunal and after exchange of Statements of Case HMRC elected to withdraw their objection.