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Tax law [2025] UKFTT 701 (TC)

Smart v Revenue and Customs (NCOME TAX - whether the appellant was liable to income tax on sums payable by overseas entities that are taxable)

Smart v Revenue and Customs (NCOME TAX - whether the appellant was liable to income tax on sums payable by overseas entities that are taxable) [2025] UKFTT 701 (TC) (12 June 2025)

The tribunal dismissed Mr Smart’s income tax appeal over BTG JCP distributions, holding he was the person receiving or entitled to the sums and rejecting rescission-based arguments.

  • Income tax
  • Foreign income
  • Taxation of overseas entities
  • Entitlement to income
  • Tax assessments
  • Rescission
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Tax law [2014] UKFTT 996

Madhusudhan v Revenue & Customs

Madhusudhan v Revenue & Customs [2014] UKFTT 996 (TC) (29 October 2014)

The tribunal dismissed a doctor’s appeal over income tax amendments and penalties, holding that overseas-business expenses were not deductible against his UK trade income.

  • Income tax
  • Incorrect returns
  • Penalties
  • Foreign income
  • Double taxation relief
  • Income-tax
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Tax law [2014] UKFTT 996 (TC)

Madhusudhan v Revenue & Customs

Madhusudhan v Revenue & Customs [2014] UKFTT 996 (TC) (29 October 2014)

The tribunal dismissed Dr Madhusudhan’s tax appeal, holding overseas-business expenses could not be set against UK income and confirming HMRC’s penalties.

  • Income tax
  • Incorrect returns
  • Penalties
  • Foreign income
  • Double taxation relief
  • Income-tax
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Tax law [2013] UKFTT 112 (TC)

Coxon v Revenue & Customs

Coxon v Revenue & Customs [2013] UKFTT 112 (TC) (08 February 2013)

The tribunal dismissed Mr Coxon’s appeal against income tax assessments on escrow account interest, holding the interest was taxable and not covered by Part 8 relief.

  • Income tax
  • Foreign income
  • Interest income
  • Offset mortgage
  • Unremittable income
  • Income-tax
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Tax law [2013] UKFTT 112

Coxon v Revenue & Customs

Coxon v Revenue & Customs [2013] UKFTT 112 (TC) (08 February 2013)

The tribunal dismissed Mr Coxon’s appeal against tax assessments on escrow-account interest credited in Cyprus, holding the interest was taxable and not unremittable.

  • Income tax
  • Foreign income
  • Interest income
  • Offset mortgage
  • Unremittable income
  • Income-tax
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Tax law [2012] UKFTT 221 (TC)

Frye v Revenue & Customs

Frye v Revenue & Customs [2012] UKFTT 221 (TC) (28 March 2012)

The tribunal held that ÂŁ159,559 received through a foreign trust structure was taxable income to Jarrod Frye and dismissed his appeal.

  • Income tax
  • Foreign income
  • Trusts
  • Dividends
  • Self-assessment
  • Tax assessments
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Tax law [2012] UKFTT 221

Frye v Revenue & Customs

Frye v Revenue & Customs [2012] UKFTT 221 (TC) (28 March 2012)

The tribunal upheld an income tax assessment on a UK resident beneficiary after finding a payment from a trust-owned company was taxable trust income.

  • Foreign income
  • Trust distributions
  • Dividends
  • Self-assessment
  • Tax assessments
  • Beneficiary liability
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Tax law [2010] UKFTT 88

Swift v Revenue & Customs

Swift v Revenue & Customs [2010] UKFTT 88 (TC) (22 February 2010)

The Tribunal held that profits from a Delaware LLC were taxable to the member as they arose, so UK tax matched US tax and double taxation relief was available.

  • Double taxation relief
  • Entity classification
  • Foreign income
  • Discovery assessments
  • Double-taxation-relief
  • Entity-classification
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Tax law [1915] UKHL TC_6_613

Kensington Income Tax Comrs v Aramayo

Kensington Income Tax Comrs v Aramayo [1915] UKHL TC_6_613 (28 July 1915)

House of Lords appeal on whether foreign income was assessable under Schedule D and the proper place of assessment under the Income Tax Act 1842.

  • Income tax
  • Foreign income
  • Place of assessment
  • Income-tax
  • Foreign-income
  • Tax-assessment
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United Kingdom decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.

Source links and collection timestamps are retained alongside the indexed records.