Tax Cases

• Claim by liquidators’ assignee against former directors for repayment of unlawful distributions and breach of duties following substantial payments made by the company pursuant to an EFRB scheme and subsequent claims by HMRC against the company for non-payment of tax

• Claim against tax adviser for loss of Entrepreneurs’ Relief on non-voting shares held by spouse

• Claim for return of compound penalty payment following CPS subsequent decision to abandon prosecutions against other taxpayers in similar cases

• Claim against three sets of advisers for failure to effect an employee incentive scheme because of various errors in descriptions and denominations of share classes and the failure to identify the errors at various stages in the implementation and exercise of the employee options

• Warranty claims against vendors of international workwear business including for VAT and other tax issues revealed after completion

• Dispute between second generation shareholders of substantial and disparate family business, involving detailed exploration of corporate restructuring, tax and inheritance issues

• Claims by Liquidator against former directors following non-payment of corporation tax in pursuance of failed tax-avoidance scheme

• Claim against solicitors and accountants for mistake in the Articles regarding capital rights attaching to a class of shares which failed to reflect the agreed, and HMRC-cleared, corporate restructuring

• Claim against solicitors/attorney under PoA and additional claim against financial adviser following unexpected tax consequences and maturity of investment bonds insured on life of donor on his death

• Claim by 21 pension fund investors against SIPP provider and offshore tax wrapper provider following misappropriation of funds to investors’ IFA

• Claim against accountant for failing to advise against tax avoidance scheme, defended on the grounds of being an introducer only

• Claim against former directors and group companies following informal winding-up/reorganisation putting assets beyond the reach of HMRC as a contingent creditor in the context of threatened challenged to tax avoidance schemes

• Claim for return of compound penalty payment following CPS subsequent decision to abandon prosecutions against other taxpayers in similar cases

• Claim for loss of Entrepreneurs’ Relief on non-voting shares held by spouse

• Claim by liquidators’ assignee against former directors for repayment of unlawful distributions and breach of duties following substantial payments made by the company pursuant to an EFRB scheme and subsequent claims by HMRC against the company for non-payment of tax

• Claim against former directors and shareholder in relation to allegedly unlawful distributions following failed tax avoidance scheme and failure to consider potential liabilities to HMRC in assessing solvency

• Claims and cross-claims between family members for failure to co-operate in company sale and resulting tax charges and for failure to honour shareholder agreements relating to ongoing profit-share entitlements

• High profile claims and counterclaims between ex-wife of a Russian oligarch and her executive manager involving allegations of tax evasion, deceit, breach of trust, wrongful and unfair dismissal

• Claim against vendors of a company for restitution and alternatively under tax indemnities following HMRC demands for PAYE on tax avoidance schemes

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