Thought Leadership
Publications
Articles, books and talks
UK Exit Tax: Could an Exit Charge Be Introduced?
Guidance on a possible UK exit charge, existing tax traps when leaving the UK and the effect of split-year treatment.
Non-Dom Reform: The Proposals
Analysis of proposed reforms to the taxation of non-domiciled individuals.
Tax on Overseas Properties: Which Laws Apply?
Consideration of the taxation issues arising from ownership of overseas property.
Principal Private Residence Relief
Commentary on the application of principal private residence relief.
Residence under the OECD Model
Analysis of residence issues under the OECD Model Tax Convention.
The Tax Plans of the Major Parties
Review of proposed tax changes affecting individuals and private clients.
Dong Yang Electronics Case C-547/18
Case commentary on VAT and fixed establishments.
Praesto Consulting UK Ltd v HMRC [2019] EWCA Civ 353
Case commentary concerning VAT input tax recovery.
Coyle Transport v HMRC
Case commentary on VAT issues arising from HMRC assessments.
Finance (No.2) Act 2017 Notes: Section 68
Commentary on statutory penalties relating to VAT fraud.
Italmoda: The Birth of the Principle of Third-Party Liability for VAT Fraud
Analysis of the development of third-party liability for VAT fraud.
Financial Reporting Council v Frasers Group PLC
Case commentary on tax litigation and regulatory disputes.
HMRC v SSE Generation Limited
Analysis of a tax appeal concerning statutory interpretation.
Forced to Continue
Commentary on Albert House and Vale Property v HMRC [2020] UKUT 373.
Arron Banks v HMRC – A Political Question
Commentary on HMRC’s information powers.
No Excuse for Delay
Commentary on Sheiling Properties Ltd v HMRC [2020] UKUT 175.
All Bets Are Off
Commentary on Fisher v HMRC [2020] UKUT 62 (TCC).
A Stable Proposition?
Commentary on SDLT refund claims.
Limits to Upper Tribunal Jurisdiction
Analysis of the scope of Upper Tribunal jurisdiction.
All or Nothing – Embiricos v HMRC [2019] UKFTT 236 (TC)
Case commentary on tax procedure and appeal rights.
Online Moderator of James Kessler KC’s “Private Client Taxation”
The leading text on international private client tax.
Cross-border Tax Controversy: US and UK perspectives
Author.
Tax losses
Current author.
Practical Inheritance Tax Planning
Former co-author.
NRCGT Chapter in Tax Planning
Former contributor.
A Handbook of EU VAT Legislation
Former co-editor.
Taxpayer Safeguards
Current author.
Exceptional Circumstances Test
Rebecca frequently lectures on private client tax issues.
Recent VAT Updates
Rebecca regularly lectures on VAT issues and recent developments.
Managing HMRC from Enquiry to Tribunal
Rebecca frequently lectures on managing HMRC from enquiry through to tribunal.