Private client review for June 2024

In this article, the June monthly update for Tax Journal, Edward Reed and Clare Wilson look at a number of private client developments.

This month, we consider a number of recent FTT decisions (L, and various third party applications relating to Osmond and Allen) which examine the concept of open justice and the circumstances in which this principle can be overridden. A new Finance Act, which was rushed through before Parliament was prorogued, contains several measures of interest to private clients. A recent trio of cases – Kalay, Bezant and Hitchins – highlights the importance of complying with prescribed time limits, and the dangers to the taxpayer and HMRC in delaying action. Williams reminds us of the circumstances in which HMRC may look back 20 years, despite the taxpayer’s behaviour being classed as careless rather than deliberate. Finally, recent reports have raised concerns about HMRC’s level of customer service.

Read the full article.