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  1. Replies
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    Sticky: Be very careful. If your earlier year is under...

    Be very careful.

    If your earlier year is under enquiry, your choice is essentially settle or fight.

    The loan charge is NOT settlement.

    If the year is under enquiry and you choose not to...
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    I think my view is that this is not another Baker...

    I think my view is that this is not another Baker Tilly exercise, but rather a copy cat from Mr Thompson.

    I have nothing to add here about the individual concerned but in the absence of any...
  3. Replies
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    So be it. I've answered all the sensible comments...

    So be it. I've answered all the sensible comments I can find and ignored those which are just negative attack ads.
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    We've looked at a few hundred settlements and...

    We've looked at a few hundred settlements and suggested this (at the client's insistence) a couple of dozen times.

    Not once has HMRC budged.

    Not saying it's not possible, just that we have had...
  5. Replies
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    Ignoring "10's of emails"? I'm pretty sure...

    Ignoring "10's of emails"?

    I'm pretty sure that even I would have noticed such a volume of traffic.

    You are unhappy - I get that. You are entitled to that opinion. You are entitled to warn...
  6. Replies
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    But probably not as well as doing what we do via...

    But probably not as well as doing what we do via an accounting/legal firm?

    Tax enquiry work, from answering simple questions to developing alternative analyses, is the preserve of managerial and...
  7. Replies
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    Well in that case I cannot help you. You are...

    Well in that case I cannot help you.

    You are of course entitled to an opinion but I suggest that without the context of what you wanted to achieve and whether we told you that was possible, your...
  8. Replies
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    I see that WTT and I have been mentioned above. ...

    I see that WTT and I have been mentioned above.

    There are two points raised.

    The first is that the poster has received a poor and unresponsive service from WTT (and others) and by extension...
  9. Replies
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    Minimum standards

    Would it be a good idea if those seeking the business of contractors via whatever route, adhered to a minimum standard and possibly a common template in how they present information?

    Would this...
  10. Replies
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    For any BG people reading this thread. There...

    For any BG people reading this thread.

    There are many parts of the letter from DOR and their suggested actions, that we address in a communication we are preparing and which will be on our own...
  11. Replies
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    Then settle and get out as soon as you can.

    Then settle and get out as soon as you can.
  12. Replies
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    I think you'll find that a separate thread with...

    I think you'll find that a separate thread with over 300k views/responses and called "Big Group" is pretty transparent on what Big Group is, how it works and what we are trying to achieve.

    I...
  13. Replies
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    The first scheme is Steed self employment version...

    The first scheme is Steed self employment version 11/12 to around 13/14. We were meant to be in a directions hearing on 3rd July. That has been postponed and we await a new date which will be between...
  14. Replies
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    If you have an HMRC statement that they expect...

    If you have an HMRC statement that they expect the trust to be "closed down", you have something that we have never seen. I really don't know how HMRC can ask for something that they cannot enforce....
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    Big Group has been mentioned and I'll respond. ...

    Big Group has been mentioned and I'll respond.

    We plan to litigate. We have two schemes on the brink and more waiting.

    Because the loan charge is now with us, we have developed a position on...
  16. Replies
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    HMRC cannot force you to close the trust so why...

    HMRC cannot force you to close the trust so why do it?

    If you do not close the trust or have the loan written off, then you pay no IHT in the settlement and HMRC claim that you may owe this is in...
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    This is blatant tax avoidance. The consequence...

    This is blatant tax avoidance.

    The consequence of method b is an HMRC enquiry, perhaps incorrect tax returns and penalties, probably a demand from HMRC executed with some prejudice.

    Don't do...
  18. Thread: Yes Umbrella

    by webberg
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    A fully compliant PAYE based umbrella will return...

    A fully compliant PAYE based umbrella will return you around low 60% of invoiced hours in terms of value.

    Anything more is tax avoidance territory.
  19. There is much wrong with the way HMRC approaches...

    There is much wrong with the way HMRC approaches big business.

    Some of this is down to political interference. Some is down to lack of staff. Some is down to lack of expertise. some is down to...
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    I'm sure that this will be looked at but...

    I'm sure that this will be looked at but "negligence" is not the right word.

    We have a self assessment system. If you have fully reported all of your income and sources of income and HMRC still...
  21. Replies
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    Sticky: Not sure I understand the question. The tax...

    Not sure I understand the question.

    The tax position is based to a degree on whether the tax year in question is under enquiry (open) or not (closed).

    The settlement terms can allow all years...
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    Just do the arithmetic - it's not that difficult.

    Just do the arithmetic - it's not that difficult.
  23. A lot of the Amazon activities mentioned are not...

    A lot of the Amazon activities mentioned are not in the UK.

    When you order something from them, it comes from Luxembourg (or did before the EU called foul and forced the Lux authorities to move...
  24. Procorre - letters advising allocation of profits

    We understand that a batch of such letters has been issued.

    These say that the profits for 2014/15 have now been agreed and the profit allocation due is equal to the overdrawn current account.
    ...
  25. Replies
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    Sticky: Probably not. If years are closed - no enquiry...

    Probably not.

    If years are closed - no enquiry - then you can leave them out.

    Or you settle closed years and leave open ones to the future litigation/debate.

    However if you have all open...
  26. Many journalists are not shy of putting out 100%...

    Many journalists are not shy of putting out 100% of lurid conclusions based on 50% of the facts.

    I have some sympathy (tax is not a "sexy" subject for click bait) but not much.

    We see it all...
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    I think I've reported before that Montpelier...

    I think I've reported before that Montpelier Professional in the UK has been placed in liquidation because they tangled with an insolvency specialist who spent a lot of time (and his own money)...
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    Avenue - FTT hearing

    We are waiting on HMRC to file a case in response to our appeal to FTT on the AVENUE structure.

    We expect that to be done in August following their application for a 90 day delay.

    Once done, we...
  29. Steed - self employed scheme 11/12 to 13/14

    Hello.

    We're preparing for litigation on the above.

    We are expecting a date for a directions hearing at FTT to be set for Q4 this year.

    Our own client database is being searched for...
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  31. Replies
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    Sounds to me as though you have a scheme in which...

    Sounds to me as though you have a scheme in which you used your own limited company?

    I'm not convinced your accountant is correct. However, you have an accountant and in theory at least, you...
  32. Replies
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    Fair enough and as this is not my thread, good...

    Fair enough and as this is not my thread, good luck with the challenge.
  33. Replies
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    Sticky: Your sentiment is correct in the theoretical...

    Your sentiment is correct in the theoretical world of reasonable people but is sadly misinformed in the real world of HMRC "maximising revenue".

    The problem begins with the word "settlement".
    ...
  34. Replies
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    I can certainly help with IHT. Loan deeds? Not...

    I can certainly help with IHT.

    Loan deeds? Not so sure. If you are asking me if I have copies of them - no I don't.

    If you are asking me if we can interpret them for tax/legal purposes if you...
  35. Replies
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    One might ask, what are YOU doing to challenge...

    One might ask, what are YOU doing to challenge this?
  36. Replies
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    Sticky: In terms of settlement, an accountant or adviser...

    In terms of settlement, an accountant or adviser is not able to negotiate. The terms are "take it or leave it". If you have been offered a better "deal" by an accountant, then ask them to base their...
  37. Replies
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    Have checked on the people behind this outfit...

    Have checked on the people behind this outfit (now blocked from liquidation probably by HMRC) and given the addresses used, fellow connections in directorships and new address, I'm not at all...
  38. Replies
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    Who told you the above? Almost certainly wrong.

    Who told you the above?

    Almost certainly wrong.
  39. Replies
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    Sticky: Be very careful. Your choice is settle or...

    Be very careful.

    Your choice is settle or fight.

    If you settle (i.e. accept HMRC's position even if you think it flawed) then you have a very fluid deadline which HMRC can - and have - used to...
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    I very much suspect that if he had an opinion, he...

    I very much suspect that if he had an opinion, he would be not permitted to express it, instead being forced to follow the HMG line.
  41. Replies
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    Go and read your contract. It probable has a...

    Go and read your contract. It probable has a start and/or payment date.
  42. Thread: BIG GROUP

    by webberg
    Replies
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    392,590

    Sticky: Thank you all for the thoughts. I view...

    Thank you all for the thoughts.

    I view criticism of our technical views and questions over our motivations as generally constructive and often I suspect ask the sort of thing that many would feel...
  43. Thread: BIG GROUP

    by webberg
    Replies
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    392,590

    Sticky: Jimmy, if you want to make personal insults then...

    Jimmy, if you want to make personal insults then you'll find that they carry more weight if we know who you are?

    I have explained why I post to these threads, many times. I have been crystal clear...
  44. Thread: BIG GROUP

    by webberg
    Replies
    1,590
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    392,590

    Sticky: Ah I see. You're suggesting that my only motive...

    Ah I see. You're suggesting that my only motive should be to keep collecting the fees and stall for as long as possible.

    If that were the case, then I would have no staff, no extensions of our...
  45. Money talks. The banks and the agencies have...

    Money talks.

    The banks and the agencies have more likely than not inserted the "no return within 6 months" rule to prevent contiguous contracting periods being viewed as one period for the...
  46. Replies
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    PM me and I'll check.

    PM me and I'll check.
  47. Replies
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    That analysis does not sound "right". Where...

    That analysis does not sound "right".

    Where the scheme involved your own limited company, settlement terms (7th November 2017) operate in one of two ways.

    Either the loan value is treated as...
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    Be very clear. HMRC has never approved of any...

    Be very clear.

    HMRC has never approved of any scheme.

    Not only is such action not possible in law, it is contrary to HMRC policy and has been for as long as I an recall.

    If a scheme...
  49. Replies
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    What you have is HMRC's dogma and alleged...

    What you have is HMRC's dogma and alleged "analysis" of the situation.

    In HMRC land, the correct amount you are taxable on is that sum invoiced by your agent/intermediary, to the end client for...
  50. Thread: BIG GROUP

    by webberg
    Replies
    1,590
    Views
    392,590

    Sticky: Yesterday we posted to the BG Forum a message to...

    Yesterday we posted to the BG Forum a message to all users of:

    Marra - Kirium - Invicta.

    These were White Collar offerings from 2006 onwards.

    We are looking to accelerate litigation on these...
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