PRACTICAL TAX PLANNING OXFORD 2014 - THREE DAY SEMINAR
32nd Annual Oxford Residential Seminar in Conjunction with Tax Chambers, 15 Old Square, Lincoln’s Inn
Chair: Robert Venables Q.C.
Date: 01/10/2014 - 03/10/2014
Price: £975.00 + VAT
KEY HAVEN PUBLICATIONS LTD
32nd Annual Oxford Residential Seminar
PRACTICAL TAX PLANNING 2014: THE RULE OF LAW UNDER ATTACK
In Conjunction with Tax Chambers, 15 Old Square, Lincoln’s Inn
Wednesday 1st to Friday 3rd October
Merton College, Oxford
The aim of this year’s residential seminar is once again to examine, in the congenial atmosphere of an historic Oxford College, practical solutions to the ever changing fiscal complications to modern life. In addition to talks, a key feature of the Conference is the group sessions, in which case studies and problem papers are considered.
Fisher v HMRC developments in Transfer of Assets Abroad
New Partnership rules
Remittances by borrowing with foreign income/gains as collateral
The Taxation of Pensions Bill (August 2014)
VAT and Land
IHT on Settlements
2014 has seen attacks emanating from HMRC on rule of Law, the Rules of Natural Justice, the Separation of Powers and Human Rights. The aim is clearly to put HMRC above the law, to bi-pass the courts, to raid our bank accounts, to gag legal advisers, and to imprison the innocent.
Never since the Glorious Revolution of 1688 has there been an attack by the Executive branch of the government in this country on the historic rights and privileges of the British people.
Taxpayers and their advisers must be more vigilant than ever to defend themselves and their hard-won and hard-preserved liberties.
Robert Venables Q.C. (Chairman)
Stephen Brandon Q.C.
James Kessler Q.C.
All of the above are barristers practising at:
15, Old Square
London WC2A 3UE.
Senior Clerk: Tony Hall. +44(0)20 7242 2744.
Wednesday 1st October
12.00 Registration Begins
13.00 Lunch Merton College
14.00 Chairman’s Introduction
To include brief reference to some Finance Act 2014 and other recent changes not specifically covered in other talks
14.05 The Attack on The Rule of Law - Robert Venables Q.C.
The Fourfold Attack on the Rule of Law, the Rules of Natural Justice, the Separation of Powers and Human Rights - Putting HMRC Above the Law - HMRC As Prosecutor, Judge and Jury - Guilty Until Proved Innocent and Guilty Even Though Proved Innocent - HMRC Powers to Bi-pass the Courts - HMRC Powers to Gag Barristers and Other Advisers - Gaoling Inadvertent and Other Non-fraudulent Taxpayers - Attacks on Charities - Suggested Lines of Defence - DOTAS Revisited
14.45 Tax Avoidance, Professional Risk and Litigation - Patrick Cannon
Civil and criminal liability for professional advisers – Mehjoo, R v Eric Evans and others and Mr and Mrs “B” · GAAR update - Developments in penalties and investigations into tax schemes - FA 2014 changes: “High risk” promoters and accelerated payment procedures - “Follower notices”: distinguishing one scheme from another
15.25 Challenging Follower Notices and Accelerated Payments - Rory Mullan
Available routes of challenge - Judicial review as an alternative to appeals - Impact of Human Rights Law
16.05 Discussion Session with Tea
16.20 The Key to VAT & Land - Etienne Wong
The default position (exempt) – the zero-rated exceptions – the reduced rate exceptions – the standard rated exceptions – the option to tax – disapplication of the option to tax – the capital goods scheme – transfer of a business as a going concern – trusts – the land-related place of supply rules"
17.00 - 18.00 Introduction to Problem Papers
The panel will discuss the problem papers and give some hints as to some possible solutions which might be explored.
19.00 Pre-dinner drinks and dinner in the Great Hall
Thursday 2nd October
09.30 Chairman’s Introduction
09.35 Partnerships - Stephen Brandon Q.C.
Finance Act 2014 Changes - Limited Liability Partnerships and Deemed Employment: Circumventing the New Rules - Partnerships with Non-Individual Partners: Circumventing the New Rules
10.20 Tax Treatment of Residential Property - Oliver Marre
Changes to CGT Principal Private Residence relief in Finance Act 2014 - An end to CGT PPR elections? - Extension of CGT on residential property to non-residents - Extension of ATED - Extension of the SDLT 15% band - A Mansion Tax? - IHT
11.05 Discussion Session with Coffee
11.20 Residence and Domicile - Setu Kamal
The New Statutory Residence Test - Recent Case Law: Daniel v. HMRC - Full-time Working Abroad - Practical Advice on How to Establish and Non-UK Residence - Double Taxation Relief and Current Position of Treaty Override - Recent Developments on Taxation of Non-UK Domiciliaries - Remittances by borrowing with foreign income/gains as collateral
12.05 Taxation of Interest and Transfer of Assets Abroad - James Kessler Q.C.
Where is the source of interest post Perrin v HMRC and Ardmore v HMRC - Why does it matter? Relevance to situs of debt-claims for IHT tax and CGT - EU Savings Directive Recent Developments - OECD Project on BEPS - Proposed criminalisation of non-fraudulent failure to declare offshore interest - EU law defence to Transfer of Asset Rules - Status of Gibraltar - Motive of defence- Multiple transferors
15.00 Pensions - A New Dawn: Flexibility v. Liberation- Amanda Hardy
Flexibility - FA 2014 - Individual Protection IP14 - Fixed Protection FP14 - Changes to Capped and Flexible Drawdown - Changes to Trivial Commutations and Taxed Lump Sums. Flexibility - FA 2015 - FA 2015 an analysis of the draft Taxation of Pensions Bill published on 6th August 2014 - Complete Freedom of Drawdown (Subject to Marginal Rates) - "Free and Independent Advice" - the Implications - QNUPS - the Future - Liberation - FA 2014 - What Does it Encompass - Changes to Registration/de-registration - the "Fit and Proper Persons Test" - Who Qualifies ? - What is the "Purpose of the Scheme" - the New Statutory Requirement Increased HMRC Information and Penalty Powers
15.45 The consultation on relevant property trust charges – a fairer way of calculating tax? - Harriet Brown
The problems with the existing provisions - Purpose of the proposed changes - How the proposed changes work - Responses to the consultation - Dealing with existing trusts - What to do now to prepare for the new legislation
16.30 Discussion Session with Tea
16.45 - 18.00 Discussion of Problem Papers in Groups
19.15 Pre-dinner Drinks
19.45 Gala Dinner (black tie Optional) in the Great Hall
Guest Speaker: Nicholas Paines QC, Law Commissioner and deputy High Court Judge.
Friday 3rd October
09.30 Continuation of Discussion of Problem Papers in Groups
10.45 Discussion Session with Coffee
11.00 Discussion of Problem Papers in Plenary Session and Questions to Speakers
Post Lunch Close of Seminar
£975 per delegate plus VAT (£195) = £1,170 (to include course notes, accommodation, meals and wines.)
For application and conditions please contact:
Key Haven Publications Ltd, PO Box 669, Oxford OX3 3AU Tel: 01865
352121; Fax: 01865 351081; E-mail: email@example.com
Key Haven Publications Ltd Terms and Conditions Conferences
Cancellations: Those confirmed in writing 21 days prior to the Seminar qualify for a full refund, subject to a £100 administration fee. Cancellations within 21 days prior to the Seminar do not qualify for a refund, although substitutions will normally be allowed at Key Haven’s discretion, subject to a £50 administration fee.
Disclaimer: Key Haven Publications Ltd reserves the right to change speakers or the programme for reasons beyond its control or on account of changes in the law.
Nothing in the talks or discussions or the notes prepared for delegates constitutes legal advice. They are simply and expression of the speakers' views put forward for the consideration and discussion. No action should be taken nor omitted in reliance on them but independent professional advice should be taken in every case. Neither the speakers nor Key Haven Publications Ltd accept any legal responsibility for them.
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