27 June 2022
Private client review for June
In this article, the June monthly update review for Tax Journal, Edward Reed and Andrew Crozier look at a number of private client developments.
Discovery assessments continue to provide tax headlines. This month, we look at two cases regarding the validity of discovery assessments: a win for HMRC in Martino in the wake of the Supreme Court's decision on staleness, whilst the taxpayer wins in McCumiskey. In Lowe, the tribunal examined the meaning of "on his behalf" in the content of allowable expenditure for CGT purposes.
Finally there is partial success for the taxpayers in two cases dealing with the validity of information notices: Wiseman is a reminder of the limits of legal professional privilege, and Hackmey demonstrates that objective reasonable belief, rather than mere subjective suspicion, is required for raising information notices.
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