I have worked with a number of trust companies and banks, in a mixture of helping clients and trustees make disclosures to HMRC and also advising on the best way to structure their affairs in a tax compliant way. During the disclosure period of the LDF and the WDF I was involved in several hundred disclosures to HMRC and helped hundreds of people regularise their tax affairs in the UK.
Attention to detail and in particular HMRC practice can prove critical. In one case where HMRC were seeking upwards of £4m in taxes and interest covering a number of years, in an enquiry, which had been ongoing for nearly ten years. Having come late to the enquiry I was asked whether there was any new technical argument I could forward. Having looked at all of the correspondence going back ten years, I noticed that there did not appear to be any opening letters that had been sent directly to the client. Once I queried this it was established that although HMRC had written to the client's agent they had never written to the client to notify him he was under enquiry. After 12 months of correspondence with HMRC, they reluctantly accepted that they did not have open enquiries into the client and as a result they closed the matter down with no tax due.
Transcontinental trust conference May 2019