SECTION 19A OF the TMA 1970 is a fairly narrow information power. As such the issue of a section 19A notice is unlikely to be a disaster provided that it is appealed against within the 30 day time limit.
Information falls within s 19A only if it meets all of three conditions:
IN A FULL enquiry, the HMRC Officer will inevitably wish to see the business records. TMA 1970, s 19A gives him the right to require them to be produced to him. But 'produced' does not mean 'sent'. It means 'bring forward for inspection'. You are entitled to produce them where you want (within reason).
SITTING ON THE fence was how I concluded my article, 'WIP RIP?', Taxation 5 May 2005, page 117 on the impact of Urgent Issues Taskforce (UITF) 40, but I promised to think further. I am now firmly of the view that work in progress is alive and well and that UITF 40 has not changed very much. I am conscious that this seems to be a minority view, so it seems sensible to explain my reasoning.
AS THE RECENTLY retired chairman of the Tax Faculty, I suspect that Mark Lee felt constrained not to tread on the toes of the ICAEW's technical department. His article last week, ' Revenue Recognition ', Taxation, 28 April 2005, p94, seemed to be saying, 'If the accounting rules have changed this is the tax implication'.
The mysteries of Chapel Wharf are explored by ROBERT MAAS FCA, FTII.
UNTIL A FEW weeks ago, Chapel Wharf was just a name to me. I did not know where it was or what it did, but I did know the name because it generates a lot of the complaints crossing my desk from Tax Faculty members. Then the Revenue invited me up to see for myself. I now know that it is in Salford and that its 1,600 staff, in addition to the 355 in the Inland Revenue Contact Centre, makes it the ninth largest employer in Salford.
A thwarted appellant, ROBERT MAAS FCA, FTII, laments the fact that his own tax appeal is not to reach the Special Commissioners.