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21 June 2007 / Gary Summers , Mark Howard , Susan Bradshaw
Issue: 7278 / Categories: Features , Tax
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The ticking time bomb (2)

The ever-changing HMRC landscape requires increased vigilance from financial professionals, say Gary Summers, Mark Howard and Susan Bradshaw

Contemporary UK law enforcement strategies—referred to in the first article of this two-part series (see NLJ, 11 May 2007, pp 660–61)—appear to have been based on previous initiatives by the Internal Revenue Service in the US. This is yet another example of the extra-territorial ambit of US statutory regulation since 9/11 which is fast becoming all-pervading.

Pasquantino

In the offshore arena, the decision of the US Supreme Court in Pasquantino v US (2005) 125 S Ct 1766 that a scheme to defraud a foreign government of tax revenue violates the US wire fraud statute providing there is a US link—despite the revenue rule, a common law doctrine prohibiting US courts from enforcing a foreign state’s domestic tax infrastructure—is highly significant. Such a link could be established if the transaction was in US dollars. Frequent worldwide travellers will appreciate the ambit of this decision, which makes the prosecution of a foreign

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MOVERS & SHAKERS

Gibson Dunn—Richard Surtees

Gibson Dunn—Richard Surtees

Gibson Dunn adds employee benefits and executive compensation practice in London with partner Richard Surtees

Laytons ETL—Alec Cameron

Laytons ETL—Alec Cameron

Laytons ETL appoints new partner and head of intellectual property disputes

Muckle LLP—Roland Fairlamb

Muckle LLP—Roland Fairlamb

Specialist associate solicitor rejoins Muckle’s leading employment team

NEWS
A series of recent decisions has clarified important principles across property law, from perpetuities to lease renewals and public rights over land
Employers cannot rely on wellbeing services alone to defend workplace stress claims after a High Court decision awarding almost £1m to an overworked employee
Andy Burnham's brand of 'Manchesterism' could offer fresh thinking on legal aid and access to justice if it reaches Westminster, according to Roger Smith, NLJ columnist and former director of JUSTICE
The constitutional fallout from a change of prime minister, rather than the politics, is under scrutiny as questions arise over the limits of executive authority in a leadership transition
The legal profession is undergoing a fundamental shift from selling services to creating technology-enabled products, according to Professor Luke Mason, Head of School of Law at Regent's University London
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