Private client review for July
This month we look at the FTT’s recent decision in Lee, which could enable taxpayers who have built or redeveloped their own houses to claim private residence relief in full on a subsequent sale of the property.
There is a warning for advisers in Johnson: white space disclosures (even if made in good faith) are not a bar to a finding of carelessness. The decision in Paul once again shows the UT’s strict approach to reopening points that either were or should have been considered at FTT level.
Kavanagh, where a taxpayer was one share short of entrepreneurs’ relief applying, serves as a reminder for taxpayers to consider carefully the tax implications of their commercial decisions as it may well be "tough luck" for those who make errors. Finally, HMRC’s recent success in challenging MDR claims continues in the case of Dower.