TAX: How to keep your clients out of court and what to do if you get there

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1 #5sblaw TAX: How to keep your clients out of court 21 February 2018 at Prince Philip House 3 Carlton Terrace London SW1 5DG hours 8.30 am Registration and breakfast

2 9.15 am Introduction Christopher Tidmarsh QC 9.20 am Public Law Challenges in the Tax Arena Amanda Hardy QC 9.50 am Film Schemes not a Romantic Comedy Ruth Hughes am Discovery Assessments Sam Chandler am Coffee Break am Trusts Tax 2018 Oliver Marre am Correcting Tax Mistakes Christopher Tidmarsh QC pm Close

3 Christopher Tidmarsh QC has a wide-ranging Chancery practice. He has considerable experience of contentious and non-contentious aspects of the administration of trusts both on and offshore. His practice includes rectification and setting aside for mistake, variation of trusts, removal of trustees/personal representatives, challenging and defending probate (capacity, want of knowledge and approval), proprietary estoppel, breach of trust claims, trust aspects of divorce proceedings, advice on tax issues, advice on administration and drafting. He recently acted in ADS v DSM (a statutory will appeal). Amanda Hardy QC Amanda has appeared this year in the Supreme Court, the High Court and the First Tier Tribunal and has been involved in litigation in many areas of direct and indirect tax, including trusts and offshore trusts (appearing in the High Court in 5 recent separate applications to vary extremely substantial trusts and in relation to the effect of Double Tax Treaty provisions on trust arrangements). Her advisory private client work focuses on offshore trusts, residence and domicile issues, divorce and pensions tax. She has written the second edition of Tolley s Statutory Residence Text (published December 2017). Ruth Hughes is on the Treasury B Panel and is involved in some of the largest, most complicated and interesting tax avoidance cases presently being litigated including the Ingenious film scheme litigation and ground-breaking Business Premises Renovation Allowance cases. She is able to bring both technical skill, strong managerial skills and extensive litigation experience to her cases. In relation to her chancery practice her written and oral advocacy has been described by the Court of Appeal as exemplary. Sam Chandler is on the Treasury C Panel and maintains a busy Chancery practice in all areas of chambers work. He regularly appears in the county courts, the High Court, the Court of Protection and the Tax Tribunals (both the FTT and the UT), both as a sole advocate and as junior counsel. He has also gained substantial experience in noncontentious Chancery work, including advising and drafting around complex issues relating to trusts and estates and their taxation. Oliver Marre has a practice encompassing all areas of tax law, both contentious and non-contentious. He appears in courts and tribunals at all levels. As well as his broad general revenue advisory work and litigation, Oliver provides advice in the context of trusts disputes, mediations, in cases before the Family Division (including complex or HNW divorce cases) and in relation to the taxation of charities and charitable donors. These notes are intended as an aid to stimulate debate: delegates must take expert advice before taking or refraining from any action on the basis of these

4 notes and the speaker can accept no responsibility or liability for any action or omission taken by delegates based on the information in these notes or the lectures.

5 Public Law Challenges in the Tax Arena Amanda Hardy QC

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33 Film Schemes not Romantic Comedy Ruth Hughes

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36 Discovery Assessments Sam Chandler

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Contentious Probate Update Swansea

Wills, Trusts and Tax Contentious Probate Update Swansea DATE: Tuesday, 14 November 2017 TIME: VENUE: 1.00 pm - 5.00 pm The Liberty Stadium, Landore, Swansea, SA1 2FA St John s Chambers Wills, Trusts and