Our People

John-New

JOHN BRASSEY
Tax Director

  • Over 13 years of Code of Practice 9 experience including:
    • £15m settlement relating to a UK resident Non-Dom who failed to notify and whom HMRC had raised assessments for £30m.
    • £7m joint settlement between HMRC and IRS
    • Nil disclosure where it was demonstrated HMRC’s information was incorrect
  • In excess of 150 LDF disclosures including
    • £7.8m settlement relating to UK res dom with a US portfolio
    • Numerous trust and foundation disclosures ensuring that future taxation is considered and in several cases
  • Managed a trust review which was UK settlor interested as well as being caught as a US Grantor trust with UK, US and Australian beneficiaries.
  • Numerous Code of Practice 8 enquiries working with the client and HMRC to ensure that the planning is understood, reviewing the implementation and operation and settling with HMRC on acceptable terms.
  • Managing an enquiry on a well-known celebrity. Initially protecting their position as their accountant, who had devised and implemented the tax planning, had ignored HMRC for over a year forcing HMRC to issue closure notices. Assessments totalled over £3m and the client wasn’t even aware of the investigation. Worked pragmatically with HMRC and settled for £1.3m.
  • Successfully negotiated with HMRC demonstrating that they were out of time to enquire into an amendment and were actually out of time to process the amendment meaning they had to repay £500,000 to our client.
  • Management of full book and records reviews to ensure HMRC only ask for information they are allowed to ask for.
  • Negotiated with HMRC to demonstrate that insurance premiums were claimed incorrectly in the business and therefore a significant seven figure insurance pay out was not taxable.
  • Specialist advice on penalty negotiations at the end of enquiries.