Areas of Practice

Rebecca is a specialist tax barrister qualified in England and Wales. She has a particular focus on private client taxation and advises high-net-worth individuals, families, trustees and professional advisers on the full range of personal and trust tax issues.

• Inheritance Tax planning, lifetime gifts, estates and disputed liabilities
• Tax residence and domicile, including the statutory residence test and changes in residence status
• US/UK dual tax issues and cross-border private wealth structuring
• Trust taxation, including the taxation of trustees, beneficiaries and complex trust structures
• Capital gains tax, income tax and the taxation of private wealth and assets
• Succession planning and the structuring of family wealth
• Property taxation issues affecting private clients

Rebecca has extensive experience in both advisory and contentious VAT work. She is regularly instructed in high-value and technically complex VAT disputes before the First-tier Tribunal and Upper Tribunal, and is often instructed by HMRC.

• VAT appeals and litigation before the FTT and Upper Tribunal
• Input tax recovery and partial exemption special methods
• Complex supply chain issues and “knew or should have known” fraud cases
• Place of supply, land and property VAT questions
• Business activity rating and the correct characterisation of supplies
• Penalties, assessments and time limit disputes
• Advisory work on the VAT treatment of novel or complex transactions

Rebecca is an experienced tax litigator. She appears regularly before the First-tier Tribunal (Tax Chamber), the Upper Tribunal, the High Court and the Court of Appeal. She is instructed by both taxpayers and HMRC.

• High-value and points-of-principle tax appeals
• Statutory construction and novel points of law
• HMRC enquiries, information powers and information notices
• Time limit and carelessness arguments
• Corporation tax disputes
• Representation of both taxpayers and HMRC in contested hearings
• Strategic advice on contentious and potentially contentious matters

Rebecca advises on a range of corporate tax issues and brings a strong UK perspective to international tax problems, particularly those affecting private clients and owner-managed businesses.

• Corporate reorganisations and reconstructions
• Corporation tax disputes and enquiries
• Group relief, losses and capital allowances
• Cross-border structuring and the interaction of UK and overseas tax rules
• Advice on the UK tax consequences of international private wealth structures