GITC Review
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The GITC Review can be viewed or printed from the links below in Adobe Acrobat form. Download Adobe Acrobat Reader if you don’t already have a copy. List of Contributions to Earlier Issues.
- Volume XVII
February 2021 - Lockdown Thoughts
by David Goldberg QC - Offshore London
by Milton Grundy and Sam Brodsky - Some Pitfalls in the Tax Treatment of Compensation Payments
by Laura K Inglis - Redomiciliation and the Semifreddo Rabbit
by Nikhil V. Mehta - A Few Points of Interest
by Laurent Sykes QC - Domicile and Tax: A Pocket Reminder
by Harry Winter
- Volume XVI Number 2
January 2020 - Plane Sailing
by Samuel Brodsky - In the Footsteps of Lord MacNaugton
by Milton Grundy - IR35 + BEPS + DAC6 = ?
by David Goldberg QC - Getting Lost in the World of Deemed Reality
by Laurent Sykes QC - Judicial Unallowable Purposes
by Nikhil V. Mehta - The Turbulent State of the Disguised Employment Regime
by Laura K Inglis - Changing Perspectives: The Public Relations Battle for Tax Advisers
by Samuel Brodsky - Crypto-Assets: The Taxation of Security Tokens
by Harry Winter
- Volume XV Number 1
April 2019 - Delay and Alternative Remedies in Judicial Review Claims Against HMRC
by Michael Firth - Disputes with HMRC: Why They Arise and How to Resolve Them
by David Goldberg QC - New Trusts
by Milton Grundy - Tax Considerations in Matrimonial Finance Cases
by Laura K Inglis - A Tale of Two Domiciles
by Nikhil Mehta
- Volume XIV Number 2
March 2018 - Consistently Inconsistent – Appeals Against Findings of Fact to the Upper Tribunal
by Michael Firth - ‘No Benefit. No Tax’ – True or False?
by Michael Flesch QC - The Criminalisation of Tax Law
by David Goldberg QC - Tax Planning in the Present Climate
By Milton Grundy - The Reasonable Senior Accounting Officer
by Nikhil V. Mehta - Tax Law and the Supreme Court
By Nicola Shaw QC
- Volume XIV Number 1
November 2016 - Why the first-tier tax tribunal definitely has judicial review jurisdiction
by Michael Firth - Where ignorant armies clash by night: how reducing the size of the state has increased its power
by David Goldberg QC - Does interest arise in the UK
by David Goy QC - The offshore trust: a very British industry
By Milton Grundy - The importance of being NRI
by Nikhil Mehta - A few points of Interest
by Laurent Sykes - Appendix I – GITC review vols I-XIII
by Paul Connor - Appendix II – Finance Act 2016
by Paul Connor
- Volume XIII Number 1
December 2014 - The Magic Behind MTIC (Statistical Reasoning in Tax Cases)
by Michael Firth - Not All Benefits Are Taxable
by Michael Flesch QC - The Senior Accounting Officer
By David Goldberg QC - SPV’s and Control
by David Goy QC - The Opaque Partnership: A Note
By Milton Grundy - Schrödinger’s Cat
by Conrad McDonnell - Foreign Collateral Damage
by Nikhil Mehta - Four Practical Points to Help Defend Your Client
by Laurent Sykes - The View From The Bench
by John Walters QC
- Volume XII Number 2
January 2014 - Tax Superpositions
by Michael Firth - Reflections on the GAAR
by David Goldberg QC - ‘Not Transparent’: The Court of Appeal’s Decision on the Delaware LLC in HMRC v. Anson
by Marika Lemos - There’s no Such Thing as a Sanofi Clause – Or Perhaps There Is
by Nikhil Mehta - Giving Away Part Of The Family Home To Avoid IHT Whilst Continuing To Live There
by Patrick Soares - Why Care is Needed in Applying The Hok Case
by Laurent Sykes
- Volume XII Number 1
June 2013 - The Taxation of Jointly Owned Property
by Michael Firth - How Clear, Transparent, Accessible & Foreseeable Is Tax Law & Practice
by David Goldberg QC - The Bond and the Short of It
by Nikhil Mehta - Dataholder Notices Under Sch. 23 Finance Act 2011
by Aparna Nathan - Capital vs. Revenue: Some Points to Bear in Mind in Disputes with HMRC
by Laurent Sykes - The Rule of Law, Tax Avoidance and the GAAR
by Patrick Way QC
- Volume XI Number 2
December 2012 - Divorce Proceedings and the Release of Conifdential Documents to HMRC
by Barrie Akin - Manorial Rights and Agricultural Property Relief
by Felicity Cullen QC - A Trap for Remittance-Basis Taxpayers: The Situs of Choses in Action
by Michael Firth - The Current Focus on Tax Avoidance
by David Goldberg QC - Onshore: The New Offshore
by Milton Grundy - Breaking the Deadlock – Resolving SME and Individual Tax Disputes by ADR
by Andrew Gotch - Vodafone, Hydra and Hercules’ Second Labour Revisted
by Nikhil Mehta - The Tax Attractions of a Deeply Discounted Security
by Patrick Soares
- Volume XI Number 1
April 2012 - Case Note – Mark Higgins Rallying v. HMRC – Partnership Residence
by Imran Afzal - Case Note – Pitt v. Holt; Futter v. Futter – the Rule in Hastings-Bass and Mistake
by Imran Afzal - Vodafone’s Supreme Court Victory in India
by Nikhil Mehta and Gareth Miles - The Statutory Residence Test Consultative Document
by Aparna Nathan - Loans to Participators: A Practical Point
by Laurent Sykes - The Disguised Remuneration Rules and Part 7A ITEPA 2003
by Patrick Way
- Volume X Number 2 – Digital book version
October 2011 - Some Reflections on Tower MCashback
by David Goldberg QC - The Shahs
by Milton Grundy - A Guide to Some of the Principal Parts of the Offshore Funds Rules – Part III
by Michael Jones - Golding and Julie Middleton (executors of Dennis Golding) v. HMRC: Working Farms and the “Character Appropriate” Test
by Marika Lemos - The Battle of Hastings-Bass – The Trustee and the Tax Adviser: Whose Liability is it Anyway?
by Nikhil Mehta - Cake and Eat It – Unconditional Sale Contract With Power to Rescind – Capital Gains Tax
by Patrick Soares
- Volume X Number 1 – Digital book version
March 2011 - Recent Tax Cases
by David Goldberg QC - Nigel
by Milton Grundy - A Guide to Some of the Prinicipal Parts of the Offshore Funds Rules – Part II
by Michael Jones - Debt Releases Taxing Times for a Corporate Debtor
by Nikhil Mehta - Finance (No.3) Bill 2011 – Employment Income Paid Through Third Parties
by Patrick Soares
- Volume IX Number 3 – Digital book version
- Domicile: Basic Principles, Common Misconceptions and Preparing for the Future
by Imran Afzal - The Uses of Trusts
by Milton Grundy - A Guide to Some of the Principal Parts of the Offshore Funds Rules – Part 1
by Michael Jones - Mediation in Revenue Cases
by Sir Gavin Lightman and Felicity Cullen QC - Individual Residence and HMRC6
by Aparna Nathan - Domestic Anti-avoidance Provisions: Treaty and EU Overrides
by Laurent Sykes
- Volume IX Number 2 – Digital book version
June 2010 - Flip Flop Schemes and Burton
by Imran Afzal - Section 42 Finance Act 1998 – An Opportunity Missed?
by Barrie Akin - Dividends: A Flow-chart of the New Regime
by Felicity Cullen QC - Mr. Lee
by Milton Grundy - Growing (Capital) Pains in Indian Taxation and Other Fiscal Ailments for Foreign Investors
by Nikhil Mehta - Treaties Which Override the IHT Deemed Domicile Rules
by Patrick Soares - Residence and Zero Rate of Tax Jurisdictions
by Laurent Sykes - Image Rights after Finance Act 2010
by Patrick Way
- Volume IX Number 1
December 2009 - Purpose or Intendment: Spot the Difference
by Michael Flesch QC - On the Nature, of Reality
by David Goldberg QC - Thoughts on Drummond and the Judicial Approach to Tax Avoidance
by Imran Afzal - Stamp Duty: an Epilogue – the decision in Parinv in aid of the taxpayer
by Marika Lemos - Some Observations on the Residence of Corporate Trustees
by Aparna Nathan - What Reverse Premiums are Tax Free?
by Patrick Soares - Property Tax Planning: the Future is Capital and Loans
by Patrick Soares
- Volume VIII Number 3
June 2009 - Smallwood: the high Court Decision
by Philip Baker QC - Sub-Funds – deem, deem, deem?
by Felicity Cullen QC - Thoughts on Corporate Residence
by David Goldberg QC - Tax Planning in Pre-packaged Administrations
by Michael Jones - Avoiding Land Trading Transactions
by Patrick Soares - The Enterprise Investment Scheme after Blackburn
by Patrick Way
- Volume VIII – Number 2
April 2009 - The Principessa
by Milton Grundy - Nelson Dance and Business Property Relief
by Marika Lemos - Contemplating Grace: The impact of RCC v. Grace on the Test for Determining Individual Residence
by Aparna Nathan - Avoiding the Order of Remittance Rules by Having a “Golden” Bank Account
by Patrick Soares - Making Sense of s.809L
by Laurent Sykes - The 2009 Reforms of the Tax Appeals Tribunals
by John Walters QC
- Volume VIII – Number 1
November 2008 - Private Foundations – An aspect of the Remittance Basis
by Felicity Cullen QC - Tax Avoidance in Practice
by David Goldberg QC - Miscellaneous Points on VAT and Property
by David Goy QC - CFC Code Removed from Statute Book by Judge
by Laurent Sykes - EBTs and FBTs after Sempra
by Patrick Way - Letter to the Editor From Tony Foreman
- Volume VII Number 2
June 2008 - Offshore Business Centres: A World Survey
by Felicity Cullen QC - Mars and Secan: There Illusion and Here Truth; the Computation of Profit
by David Goldberg QC - Case Note: Smallwood v. Revenue & Customs Commissioners
by Milton Grundy - Every Second Counts: Limits on HMRC’s Power to Recover NICs
by Michael Jones - Using Family Trading Trusts for Land Deals – Stopping Tax at the Basic Rate
by Patrick Soares - The Changes to the Remittance Basis and New Structures
by Patrick Soares
- Volume VII – Number 1
December 2007 - Depreciation and Trading Stock – Confusion Unconfounded
by Barrie Akin - “Benefit”: A Note
by Milton Grundy - The United Kingdom as an Offshore Centre
by Aparna Nathan
- Volume VI – Number 2
June 2007 - Beneficiaries of Trusts and Foundations
By Philip Baker QC - The Ordinary and Extraordinary Power of the European Court of Justice
By David Goldberg QC - The Smith Story
By Milton Grundy
- Volume VI – Number 1
February 2007 - Compulsory Purchase and Rollover Relief
By Barrie Akin - Beneficial Ownership – after Indofood
By Philip Baker QC - The Music Between the Notes: A review of “More Essays in International Tax Planning” by Milton Grundy
By Conrad McDonnell - Cyganik v. Agulian: Determining Domicile of Choice
By Aparna Nathan - Litigate or Die
By Patrick Way
- Volume V – Number 2
May 2006 - Tax Aspects of Rectification
By Barrie Akin - Payments for Share Capital and s.419 ICTA 1988
By Felicity Cullen - Double Tax Treaties and ss.739 and 740 ICTA 1988
By David Goy QC - College of Estate Management v. Customs & Excise Commissioners [2005] STC 1597: Case Note and Commentary
By Nicola Shaw - If Ramsay Were in Statutory Form
By Patrick Soares
- Volume V – Number 1
November 2005 - Company Residence after Wood v. Holden
By Aparna Nathan - Section 80 TCGA 1992: in Breach of Community Law?
By Claire Simpson - Points of View
By Patrick Soares - Individual Residence and s.334
By John Walters QC - Dextra – Its Not Over Till the Fat Lady Sings and Other Cliches
By Patrick Way
- Volume IV – Number 2
May 2005 - The Problem is Perception
By David Goldberg QC - Treaty-Shopping through Life Assurance
By Milton Grundy
- Volume IV – Number 1
November 2004 - Book Review: “The Saving of Income Tax, Surtax and Death Duties” by Jasper More
By Philip Baker QC - Words From The Heart: Tax Avoidance of the Third Kind; the Lessons of Schrodinger’s Cat
By David Goldberg QC - Disclosure
By Patrick Way
- Volume III – Number 2
April 2004 - The World-Wide Response to the Harmful Tax Competition Campaigns
By Philip Baker QC - No Loss All Gain for Non-resident Companies
By Felicity Cullen - Property Dealers: Why not set up your own FURBS?
By Patrick Soares - VAT and alterations to listed buildings – the Zielinski Baker appeal
By John Walters QC - The Ramsay principle: where are we now?
By Patrick Way
- Volume III – Number 1
November 2003 - Stamp Duty Land Tax by Michael Thomas – A Review
by David Goldberg QC - Home Thoughts from Abroad
By Milton Grundy - Just Supposing ….
By Hugh McKay - MARD – Issues arising from the Mutual Assistance in the Recovery of Debts Directive
By Aparna Nathan
- Volume II – Number 2
April 2003 - Tax and Damages (1)
By Conrad McDonnell - Tax and Damages (2)
By Harvey McGregor QC - Tax and the Proceeds of Crime
By Nicola Shaw - The Influence of the European Court – Recent and Forthcoming Tax Cases
By Claire Simpson - Tax and Damages (3)
By John Walters QC - Employee Benefit Trusts
By Patrick Way
- Volume II – Number 1<
November 2002 - The Application of the Convention to Partnerships, Trusts and other, Non-Corporate Entities
By Philip Baker QC - The Legal Adviser’s Responsibility
By David Goldberg QC - Disposals by Companies With Substantial Shareholdings
By David Goy QC - The Limited Partnership: A UK vehicle for non-residents with non-UK income
By Milton Grundy - IHT Planning – the Gift With Reversion Approach
By Patrick Soares - Modernising Stamp Duty on Land and Buildings in the United Kingdom
By Patrick Way
- Volume I – Number 2
May 2002 - Section 739 and Foreign Domiciliaries: Some Reflections
By Michael Flesch - The Offshore Trust in Barbados
By Milton Grundy
- Volume I – Number 1
November 2001 - Anti-Avoidance
By David Goldberg - Information: Compliance v Confidentiality
By John Walters