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Inland Revenue Commissioners v Willoughby and Another: CA 6 Jan 1995

Anti-avoidance provisions do not catch a transfer of assets which were located abroad and which made at a time when the taxpayer was a non UK resident. Citations: Gazette 08-Mar-1995, Ind Summary 13-Feb-1995, Times 06-Jan-1995 Statutes: Income and Corporation Taxes Act 1988 739-741 Jurisdiction: England and Wales Citing: Appealed to – Inland Revenue Commissioners v … Continue reading Inland Revenue Commissioners v Willoughby and Another: CA 6 Jan 1995

Swift v Revenue and Customs: FTTTx 22 Feb 2010

FTTTx DOUBLE TAXATION RELIEF – individual investor in Delaware LLC – whether entitled to the profits as they arise – yes – accordingly the Appellant is entitled to credit for US tax paid by him, the LLC being transparent for US tax purposes – if wrong, the LLC is not treated as transparent by s … Continue reading Swift v Revenue and Customs: FTTTx 22 Feb 2010

Anson v Revenue and Customs: SC 1 Jul 2015

Interpretation of Double Taxation Agreements This appeal is concerned with the interpretation and application of a double taxation agreement between the United Kingdom and the United States of America. A had been a member of an LLP in Delaware, and he was resident within the UK, but not domiciled here. He was liable to UK … Continue reading Anson v Revenue and Customs: SC 1 Jul 2015

Revenue and Customs v Anson: CA 12 Feb 2013

The revenue sought to levy income tax on the taxpayers share of revenue in a Delaware Limited liability company. In the US the company would itself be liable for and pay all tax on the members’ profits. Mr Anson was resident but not domiciled in the . .

HMRC v George Anson: UTTC 3 Aug 2011

UTTC Income tax – double taxation – United Kingdom and United States – whether computation by reference to the same income or profits – whether taxpayer entitled to profits as they arise . .

HMRC v Anson: UTTC 16 Feb 2012

UTTC Income tax – whether taxpayer can invoke section 739 of the Income and Corporation Taxes Act 1988 as against HMRC – effect of sections 739-741 – can costs be awarded in the Upper Tribunal on an appeal from . .

HMRC v Anson; UTTC 16 Feb 2012

References: [2012] UKUT 59 (TCC) Links: Bailii Coram: Mann J UTTC Income tax – whether taxpayer can invoke section 739 of the Income and Corporation Taxes Act 1988 as against HMRC – effect of sections 739-741 – can costs be awarded in the Upper Tribunal on an appeal from the First-Tier Tribunal. Statutes: Income and … Continue reading HMRC v Anson; UTTC 16 Feb 2012