Are you or your client facing a tax investigation and/or a 60% penalty (or worse) for a tax scheme defeated by HMRC using the General Anti-Abuse Rule or GAAR or you are an adviser who enabled a tax scheme that has been defeated by HMRC and are facing potentially ruinous enabler penalties as a result?
If so you should seek specialist advice from a legal adviser with experience and a proper understanding of the GAAR. The GAAR and its related penalties is a highly specialised and complex area of tax law and Patrick Cannon is the author of GAAR: A Practical Approach and has over 30 years experience as a solicitor and then a barrister successfully defending clients in HMRC tax investigations both criminal and civil. Patrick is authorised by the Bar Standards Board to accept Public Access work and to conduct litigation, that is to accept work directly from clients and to deal directly with HMRC on their behalf.
Patrick works on the basis of fixed fees agreed by the client in advance with his Clerk instead of open-ended hourly rates. If you have a GAAR or related penalty enquiry please contact Patrick Cannon here for an initial discussion.