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Adecco UK Ltd & Ors v Revenue & Customs, [2018] EWCA Civ 1794-- summary under Agency Summary Under Tax Topics- General Concepts- Agency a placement service providing non-employee temps to clients was not paying the temps’ compensation on the clients’ behalf An employment bureau (Adecco) introduced temporary staff ("temps"), who were not Adecco employees, to clients looking for a temporary worker to undertake an assignment, and if the temps accepted an assignment, Adecco paid them for the work they did for the clients – and collected those amounts plus a mark-up from the clients. ...

Hill & Anor. v. C. & E. Cmners., [1988] BTC 5139 (QBD)-- summary under Agency Summary Under Tax Topics- General Concepts- Agency A commercial gallery successfully argued that it was selling pottery as agent for some potters, rather than as principal. ...

Royal National Institute for the Blind & Ors, [2014] BTC 24, [2014] EWHC 1373 (Ch)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission specific intent to accomplish a particular devise at the time of botched drafting The claimant applied for rectification of a Deed of Variation which altered the provisions of the will of Hilda Bolton with a view to reducing the incidence of inheritance tax, pursuant to s. 142 of the Inheritance Tax Act 1984, which permitted the effecting a deed of variation within two years of the date of death in order to redirect gifts passing under a will. ...

Goldcorp Exchange Ltd & Ors v. Leggett & Ors, [1994] UKPC 3, [1995] 1 AC 74-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership no ownership of unascertained goods At the time banks appointed receivers for a dealer in precious metals, the dealer had a stock of precious metal bullion that was substantially less than that which was required to satisfy contracts of the public for purchases of precious metals for future delivery. ...

(Prudential plc & Anor) v. Special Commissioner of Income Tax & Anor, [2013] 2 All ER 309, [2013] UKSC 1-- summary under Solicitor-Client Privilege Summary Under Tax Topics- General Concepts- Solicitor-Client Privilege In dealing with a claim of privilege asserted with respect to tax advice provided by an accounting firm on a tax shelter transaction, Lord Neuberger stated for the 5-2 majority that, although the rationale for legal advice privilege applies as readily to accountants who provide tax advice as to solicitors or barristers doing the same, such privilege should nevertheless be restricted to lawyers. ...

Pope & Ors v. R & C Commrs., [2012] UKUT 206 (Tax and Chancery Chamber)-- summary under Subsection 104(13) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13) The son of the taxpayer, who was the beneficiary of his own life insurance policy, likely died in 1998 when he was abducted by Angolan rebels, but this was never conclusively established. ...

Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. ...

Lavallee, Rackel & Heintz v. Canada (Attorney General); White, Ottenheimer & Baker v. ...

Kucor Construction & Developments & Associates v. Canada Life Assurance Co. (1998), 41 OR (3d) 577 (Ont. ...

Lanman & Kemp-Barclay & Co. of Colombia v. Commissioner of Internal Revenue, 26 TC 582 (1956)-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax The Republic of Colombia levied, pursuant to the same tax statute under which an income tax and an excess profits tax was levied, a capital tax (referred to as a "patrimony tax") which was "based on the theory that the income tax, in order to be an equitable revenue system, requires a tax on capital to more fairly distribute the burdens amongst the nation's taxpayers and to prevent the state from being penalied if a property owner, through negligence or for some other reason, fails to realize the inherent productive potential of his property" (p. 587). ...