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ROSALIND BURNS
Tax Manager

  • Managed a substantial “full books and records” check by HMRC into a well-known corporate across several years, which included:
    • An assessment for c.£700,000 on one specific payout. This was appealed on the client’s behalf and, following nearly a year of specialist negotiations, HMRC agreed to void the notice
    • Multiple claims to the county courts by HMRC for NICs irregularities, all of which were successfully appealed
    • A full “IDEA review” of the corporate’s electronic systems
    • A concurrent enquiry into the owner of the business covering several onshore and offshore elements, including substantial interaction with the corporate accounts
  • Managed and dealt with numerous Code of Practice 9 “Civil Fraud” investigations, both prior to and following the introduction of CDF (Contractual Disclosure Facility), including:
    • Voluntary registration for a teacher who had undeclared tuition income outside of his employment, for which minimal penalties were calculated
    • A large, multi-tax, detailed investigation by HMRC, which involved multiple parties represented by other advisors
    • Undertaking a “watching brief” over the investigation of a CTA who had promoted several prominent tax avoidance schemes to ensure that HMRC did not obtain confidential information in respect of third parties and that our client was not penalised for matters unrelated to his personal affairs
  • Advised on and managed in excess of 100 offshore and onshore tax disclosures, including
    • A £1.34m settlement for a recently bereaved widow who had suddenly inherited multiple offshore companies and trust structures in her late husband’s name
    • Several “Let Property Campaign” disclosures, through which various clients have also disclosed other irregularities in order to neatly bring their wider affairs up to date.
  • Undertook a review of an offshore Foundation prior to the deadline for LDF (Liechtenstein Disclosure Facility) registration, to advise whether their beneficiaries may have a UK tax exposure on the distributions made over the past 20 years.
  • Has represented and guided several clients through Code of Practice 8 “Fraud and Bespoke Avoidance” negotiations with HMRC, which can often be highly technical and complex for a taxpayer to follow.
    • Includes ensuring that the client is not penalised for a technical viewpoint.
  • Has experience of advising and guiding clients through the “Alternative Dispute Resolution” process prior to taking their appeal to the Tax Tribunal, where appropriate.
  • Negotiated multiple “Time to Pay” arrangements for clients to settle their liabilities and has provided specialist advice on HMRC powers, including time limits and negotiating the appropriate penalty loadings (if any). Significant experience of dealing with Information Notices and advising on their validity.
  • Regularly undertakes risk reviews for individuals and corporates in respect of their UK affairs and how HMRC are likely to view certain arrangements, including quantification of likely liabilities for indemnity/warrantee purposes upon corporate sales and purchases.
    • This includes reviews of trusts and other structuring arrangements.