GITC Review

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• Volume XVIII
  April 2022
• Some Thoughts on Avoidance
  by Milton Grundy
• A Speech to Mark the Publication of “taxation of Partnerships and LLPs” by Damien Crossley and Mark Baldwin
  by David Goldberg QC
• A Few Points of Interest
  by Laurent Sykes QC
• Tax Avoidance Purpose Winner Takes All (Again)
  by Nikhil V. Mehta
• The Limits of Limited Liability
  by Michael Firth
• Disguised Tax
  by Samuel Brodsky
• Gifts With Reservation of Benefit? Nil Desperandum!
  by Harry Winter

• 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