Search Results - Contractor UK Bulletin Board

Search:

Type: Posts; User: webberg

Page 1 of 10 1 2 3 4

Search: Search took 0.01 seconds.

  1. Replies
    121
    Views
    12,057

    IF we were allowed to and IF I was inclined, I...

    IF we were allowed to and IF I was inclined, I could list perhaps a dozen schemes that are up and active.

    For the avoidance of doubt I would not recommend any of them.
  2. Replies
    121
    Views
    12,057

    With respect, you have fallen into the trap set...

    With respect, you have fallen into the trap set by HMRC's PR people.

    "Taxpayers may use an avoidance scheme" my emphasis - and "penalised for evasion" -my emphasis.

    Not the same and the tests...
  3. You can and this in the present context is...

    You can and this in the present context is perhaps where the value of a professional starts to be felt.

    The general concepts of a defensive strategy are all here in these threads but to put them...
  4. HMRC will point to GAAR opinions from last...

    HMRC will point to GAAR opinions from last October which say that the third party requirement is "not what Parliament intended".

    How do you argue that away?
  5. There is no such thing as "people who haven't...

    There is no such thing as "people who haven't needed to complete tax returns".

    If you are liable then you have a legal obligation to file a return.

    If they decide to ignore their legal...
  6. Yes. Settlement and loan charge operate on...

    Yes. Settlement and loan charge operate on different definitions of chargeable loans.

    Settlement is ALL loans.

    Loan charge is loans within the legal definition.

    Not sure what the "challenge"...
  7. Let me attempt a summary of a point and a thread...

    Let me attempt a summary of a point and a thread that is spiraling.

    Loan Charge

    HMRC's default position is that if you have used what they call (but do not define) a disguised remuneration...
  8. If the party paying the advisers fees is the...

    If the party paying the advisers fees is the promoter, then - with some really rare exceptions - the words you use above are not from the adviser. They are the words of the promoter often putting a...
  9. I don't know what "IR Regulations" means. Read...

    I don't know what "IR Regulations" means.

    Read your documents.

    Get a piece of paper and draw five boxes left to right across the paper.

    Box 1 is the end client. Box 2 is the agency. Box 3 is...
  10. Ten minutes researching the scheme would give you...

    Ten minutes researching the scheme would give you an answer.
  11. Bear in mind that an adviser "advises". An...

    Bear in mind that an adviser "advises". An adviser does not make decisions for you. In going to an adviser you are seeking knowledge and an opinion. You are not paying somebody to assume your legal...
  12. Replies
    121
    Views
    12,057

    No, "another" simply means "not you". It could...

    No, "another" simply means "not you".

    It could be a tax adviser, brain surgeon, bin man, random stranger in the street.
  13. Replies
    121
    Views
    12,057

    Not sure I'm very happy about a statement I've...

    Not sure I'm very happy about a statement I've made being edited in such a way as to have it say something I did not say or intend.

    I'd appreciate you taking steps to show that YOU have inserted...
  14. Replies
    121
    Views
    12,057

    I have no idea if you are correct or not. I...

    I have no idea if you are correct or not.

    I have no idea what the final wording may mean or how HMRC may interpret it or how a Court may interpret it.

    What we will do, if the legislation is...
  15. Replies
    121
    Views
    12,057

    You are paying a tax expert to explain to you...

    You are paying a tax expert to explain to you your obligations and how what is being filed meets or falls short of those obligations.

    Their duty is to explain the benefits and risks of what you...
  16. Replies
    121
    Views
    12,057

    Incorrect in my opinion. If you knew or...

    Incorrect in my opinion.

    If you knew or suspected that the adviser/scheme promoter and or independent agent were telling you to do something that was tax avoidance then any defence you might have...
  17. Replies
    121
    Views
    12,057

    I think you are placing a heavy burden on...

    I think you are placing a heavy burden on legislation that has not passed into law and trying to second guess it at this stage is an impossible task.

    In general however, we have a self assessment...
  18. Replies
    121
    Views
    12,057

    As I said the assessments were on the EMPLOYER. ...

    As I said the assessments were on the EMPLOYER.

    The liability can be transferred via Reg 81 but there are a number of conditions to be met. I suspect that HMRC may have struggled with those.
    ...
  19. Replies
    121
    Views
    12,057

    I don't know I'm afraid.

    I don't know I'm afraid.
  20. Replies
    121
    Views
    12,057

    I know I'm being pedantic here, but it's...

    I know I'm being pedantic here, but it's important.

    The various schemes were designed to take advantage of tax laws as they were at the time. Some of them also considered the then judicial...
  21. Replies
    121
    Views
    12,057

    Think you'll find that this is not the case. ...

    Think you'll find that this is not the case.

    The cases post Rangers are all sub judice and there is a long way to go.
  22. Replies
    121
    Views
    12,057

    Please read the case. It was not about whether...

    Please read the case. It was not about whether the scheme worked or not. It was about whether it should have been disclosed for the purposes of DOTAS.

    To the best of my knowledge there is no...
  23. Replies
    121
    Views
    12,057

    1. Yes I believe it does mean that because the...

    1. Yes I believe it does mean that because the scheme has been held to be "disclosable", it will have a DOTAS SRN and an APN can be issued. I have no idea if such action is going to happen.

    2. I...
  24. Replies
    121
    Views
    12,057

    Revenue & Customs v Hyrax Resourcing Ltd & Ors...

    Revenue & Customs v Hyrax Resourcing Ltd & Ors (INCOME TAX/CORPORATION TAX : Anti-avoidance) [2019] UKFTT 175 (TC) (05 March 2019)

    I think K2 was registered for DOTAS but Hyrax was not.

    The...
  25. Replies
    162
    Views
    72,554

    Network One and its successors Quantum and...

    Network One and its successors Quantum and Endeavour have a group of users who are contesting HMRC's version of the truth.

    This is the CCR Group.

    I can put you in touch with them if you PM me....
  26. And WTT continues to contest HMRC's version of...

    And WTT continues to contest HMRC's version of the truth.

    And again, how, why, when and where we do that is available to clients.

    Again, our clients seem to be happy that we are progressing as...
  27. Disappeared? No - still very much here. Are...

    Disappeared? No - still very much here.

    Are our clients happy with us and our progress? Judging by communication traffic, attendance at client webinars, requests for help etc - I would say the...
  28. Replies
    1
    Views
    728

    Some umbrellas leak

    Comparison and broker websites marketing umbrella companies are not always what they seem (Spotlight 55) - GOV.UK

    Most of you probably know this already, but a useful reminder.
  29. Thread: BIG GROUP

    by webberg
    Replies
    1,611
    Views
    440,937

    Sticky: Members will have noticed that the BG forum is...

    Members will have noticed that the BG forum is presently closed and will remain closed for a period.

    If you have any questions, please email us info@wttconsulting.co.uk or call us or email your...
  30. Replies
    95
    Views
    15,899

    I see the thread here continues to attract...

    I see the thread here continues to attract comments.

    I have a responsibility to my clients. In my view I would be failing in that if I discuss in open forum why we and our legal team consider that...
  31. Replies
    95
    Views
    15,899

    Happy to discuss both the above but not on this...

    Happy to discuss both the above but not on this thread.
  32. Replies
    95
    Views
    15,899

    If you're going to criticise at least try to get...

    If you're going to criticise at least try to get the numbers right please.

    If there were 3k people (there are not), at £15 that's £45k, not "over £50k".

    We've been running it around 5 years.
    ...
  33. Replies
    95
    Views
    15,899

    If you're going to criticise, please gets the...

    If you're going to criticise, please gets the facts rights.

    It's £15 plus VAT.
  34. Replies
    95
    Views
    15,899

    Same post twice - an error? I'm here until 5pm...

    Same post twice - an error?

    I'm here until 5pm and then not until Sunday.
  35. Replies
    95
    Views
    15,899

    Is that a yes to a meeting or a no? I'm not...

    Is that a yes to a meeting or a no?

    I'm not sure who you are referring to when you say "former Counsel" and "current Counsel"?

    We have used the same Counsel since the beginning and have...
  36. Replies
    95
    Views
    15,899

    We could do this like professionals. Let's set...

    We could do this like professionals.

    Let's set up a (virtual) meeting between us, our Counsel, you and your Counsel. Invite RPC if you wish.

    We can have an exchange of expert views without the...
  37. Replies
    95
    Views
    15,899

    With respect (and not knowing who you are or why...

    With respect (and not knowing who you are or why you have not contacted us directly) I would disagree with your adviser.

    Clearly I have no idea how well versed or otherwise that adviser may be in...
  38. Replies
    95
    Views
    15,899

    Thank you for your commentary Saleos. Your...

    Thank you for your commentary Saleos. Your contribution to the discussion in this forum, which is more conducive to considered analysis than its 280-character counterpart, is appreciated.

    Whilst...
  39. Replies
    32
    Views
    8,232

    Sticky: I can see how useful that could be where interest...

    I can see how useful that could be where interest has not been demanded within the given period but presumably until a repayment demand for the principal is made, the period cannot start?

    I would...
  40. Replies
    95
    Views
    15,899

    The application of Mr Hoey to appeal against the...

    The application of Mr Hoey to appeal against the refusal to hear a Judicial Review action was heard - remotely - today.

    The application was refused on the grounds that it had no prospect of...
  41. Replies
    32
    Views
    8,232

    Sticky: I know that updating my own post is a bit gauche,...

    I know that updating my own post is a bit gauche, but I think it's justified.

    MTM Consultants have issued demands from their new head office. These demands relate to a success fee that is dressed...
  42. How could Felicitas have got hold of a ruling...

    How could Felicitas have got hold of a ruling obtained by another company?

    Clearly there is a conspiracy going on here that I'm unaware of.
  43. How could they have got a pre-emptive Court...

    How could they have got a pre-emptive Court decision? Just not possible. There is a process, they have to begin with a request for payment, then press that demand, then if not paid go to the court....
  44. I've heard a number mentioned that I've...

    I've heard a number mentioned that I've discounted as scuttlebutt.

    Even if we go for half of that though, £500m.

    How much did they pay?

    I have no idea. I'm guessing very little upfront with...
  45. Replies
    32
    Views
    8,232

    Sticky: Is it the case that the period begins when the...

    Is it the case that the period begins when the first instance of possible repayment arises?
  46. There are probably a number of strategies...

    There are probably a number of strategies available to those being asked to repay loans. Some are passive, some are active.

    The passive strategies will be relying upon the owner of the alleged...
  47. I would add that some people who are now clients,...

    I would add that some people who are now clients, paid some of the demands prior to joining us, and we and they have been unable to recover those sums.

    The loan holders here rely upon a certain...
  48. See above. You are of course entitled to a...

    See above.

    You are of course entitled to a view and opinion.

    Where that includes suggesting a strategy - active or passive - it might help if we knew something about your knowledge or...
  49. Replies
    32
    Views
    8,232

    Sticky: I have no control over what is posted by whom, so...

    I have no control over what is posted by whom, so as long as it's relevant and helpful, I see no reason why you should not post as you see fit.
  50. Sorry, being a bit dim this morning. Does this...

    Sorry, being a bit dim this morning.

    Does this mean you will do nothing and hope that Felicitas et al give up?

    Or does it mean that you hope over time Felicitas will collect enough to keep even...
Results 1 to 50 of 500
Page 1 of 10 1 2 3 4