This podcast discusses the Tax Appeals Commission concerning an appeal against an income tax assessment for the 2014 tax year, connected to participation in Liberty Syndicates, which involved complex transactions with British Virgin Islands companies designed to generate tax losses. The appeal is determined without a hearing based on previous Commission determinations (32TACD2020 and 53TACD2020) regarding the Liberty Syndicates, which were upheld by the High Court and Court of Appeal. The key issues mirror those in the prior cases: whether participation constituted a trade in financial instruments, the application of section 812 of the TCA 1997 to foreign dividend income, and the validity of the appellant's expression of doubt on their tax return. Since the appellant presented no new arguments, the Commission finds the assessment should stand, consistent with the prior rulings.

84TACD2025 - Income Tax

This podcast discusses an appeal to the Tax Appeals Commission regarding an income tax assessment for the year 2012, stemming from the appellant's participation in the Liberty Syndicates. The Commission determined the appeal without a hearing, referencing previous determinations and related High Court and Court of Appeal judgments concerning the same syndicate arrangements. These prior rulings established that participants were not engaged in trading, the dividend transactions were primarily for generating tax losses, and the foreign dividend income was taxable. The document concludes by upholding the original income tax assessment.

92TACD2025 - Income Tax

Buy the course here: https://shoppy.gg/product/SCaSxBj

Or contact Maris.amandateam@gmail.com for 10% DISCOUNT for PAYPAL and 20% for CRYPTO

More courses at: https://t.me/amandateam24h/4

Websites: Course24h.com    |    Shoppycourses.com   |   Glocourse.com

[COurse24h.com] Andrew Foxwell – Assessment Action Ascension Version 2.0

This podcast outlines a tax appeal to the Tax Appeals Commission regarding an income tax assessment from 2011. The appeal stems from the appellant's involvement in Liberty Syndicates, which engaged in dividend purchase transactions with British Virgin Islands companies. Previous related appeals in 2019 were unsuccessful for the appellants and were subsequently upheld by both the High Court and the Court of Appeal. As this current appeal presents common issues and the appellant offered no differentiating arguments, the Commissioner determined it without a hearing, referencing the outcomes of the prior cases, and upheld the tax assessment.

111TACD2025 - Income Tax

This podcast concerns a determination from the Tax Appeals Commission regarding an appeal against an income tax assessment for the 2012 tax year, brought by an Appellant against the Revenue Commissioners (the Respondent). The appeal is one of several "Liberty appeals" concerning participation in Liberty Syndicates, complex arrangements involving the purchase of dividend rights from offshore companies, designed to generate tax losses. The Commission's decision to determine this appeal without a hearing, relying on previous decisions and court judgments related to other Liberty Syndicate cases, is upheld because the Appellant did not differentiate their case or object to this procedure. The key issues addressed, aligning with prior rulings, include whether the Syndicate activities constituted trading (found not to be the case), the applicability of a specific tax law (found not to apply), and the validity of the Appellant's expression of doubt regarding their tax return (found not to satisfy legal requirements). Ultimately, the income tax assessment for 2012 is confirmed.

116TACD2025 - Income Tax

This podcast discusses a First-Tier Tribunal Tax Chamber decision regarding Kearney Transport Ltd's hardship application against HM Revenue and Customs (HMRC). Kearney Transport Ltd, assessed for £69,281 in excise duties, sought to proceed with an appeal without prepayment, claiming that upfront payment would cause the company undue hardship. The Tribunal heard evidence from Mr. Kearney, a director of the appellant company, and reviewed financial accounts from March 2024. Ultimately, the application for hardship was rejected because the appellant failed to sufficiently demonstrate that paying the duty would cause hardship, as the financial information provided was deemed unclear and incomplete.

Kearney Transport Ltd v HMRC [2025] UKFTT 593 (TC)

This podcast discusses a determination from the Tax Appeals Commission regarding an appeal concerning income tax assessments for 2011 and 2012. The appeal stems from an individual's participation in Liberty Syndicates, which engaged in complex transactions involving the purchase of dividend rights from British Virgin Islands (BVI) companies. The core dispute revolves around whether these syndicate activities constituted a tax-deductible trade or an investment, and if certain foreign dividend income was exempt from Irish tax under Section 812 of the TCA 1997. The Commissioner, leveraging previous related judgments from the High Court and Court of Appeal, upheld the Revenue Commissioners' original tax assessments, concluding that the appellant's activities were not a trade and the dividend income was taxable. The decision was made without a new hearing, as the appellant did not differentiate their case from prior, similar appeals.

130TACD2025 - Income Tax

I know you're going to love this class. My 4 guest teachers were Astrid Cruise, Lisa Sack, Indu Vashist, and Jacqui Neurauter. Potpourri means a bit of this and a bit of that. This class contains a selection of movements I hope you all practice and include in some of your movement sessions. I started the class with a standing head to toe movement series related to the Green Light, Red Light, and Trauma Postural Patterns. Indu Vashist led a ribcage movement in which we followed our sternum (breastbone) in the 4 cardinal directions of up, down, to the right and to the left. From the 4 directions we then created a circular pattern in all directions. Next came Jacqui Neurauter leading a series of psoas movements with a number of wonderful variations. Then came Lisa Sack leading a series of movements involving the gluteals and the TFL, tensor fascia lata. Last came Astrid Cruise, who led a fascinating series of movements in which the pelvis rotated around the hip joints instead of the hip joints rotating within the hip sockets of the pelvis. You never know where you are going to be more challenged than you expected. I hope you have a wonderful learning experience.

6/7/25: Zoom Class: Hanna Somatic Education Potpourri, Four Guest Teachers and Myself

Karen continues recalibrating the 8 basic movement lessons in the book Somatics, by Thomas Hanna. In this class she focuses on the third lesson, pp. 112-115, controlling the muscles of the waist. She continues to brilliantly update some of the language, content, and choice of movement examples based on her experience working with clients and teaching classes.  

After some guided assessment in sitting, she had us lie down on the floor. 
Most of this session was done in side-lying. Even though many of us sleep on our side, we often leave out side-lying and lateral movements in our daily practices. Karen is very precise in her instructions which helps us to pay attention to how we are organizing ourselves. Her guidance often leads us to challenge our expectations which may confront our comfort levels. Many of us have habituated side tilts and twists in our daily movements with no awareness that this is happening. Due to the way Karen is able to break down movements, we often begin to pick up these habituations. For example, as she led us through various side bending movements many of us began to notice how much we actually lean backward in our upper body as we side bend. With repetition and moving slowly, many of us experienced how we were able to self correct and not repeat our habitual movements, but move with a new awareness. We worked both sides of our body. When we got up and walked at the end of the session, I personally felt not only more balanced but also more 3 dimensionally aware of my body.

7/5/25: Zoom Class: Recalibration of Lesson 3 from "Somatics" by T. Hanna, Guest Teacher Karen Meyer

Astrid, herself, described the focus of this class as creating space and control in the hips, pelvis and thoracic spine to enhance stability, mobility, and core connection. Astrid guided us beautifully with great clarity, an  emphasis of both exploration and self sensing at an easy to follow, slow pace. She basically had us explore four movements of the pelvis and lower extremity. Astrid built each movement sequence carefully starting with a basic movement and then guiding us to notice different aspects in the way we were using our body. She often added an additional aspect to the movement such as an oppositional rotation in the upper body with a focus on the thoracic spine. Sometimes she cued us to notice where our stability was coming from, sometimes she cued us to notice our breath or if we were adding an unconscious rotational or lateral flexion aspect. She helped us differentiate between rotating the head of the femur in the hip socket versus  rotating the hip socket around the head of the femur. It was a wonderful class with lots of learning. Thank you Astrid.

8/2/25: Zoom Class: Finding Your Center, Stabilize & Mobilize, Guest Presenter Astrid Cruse

Disclaimer: These recordings are for educational purposes only.  Please do all somatic movements comfortably, slowly, and without pain or force. Please consult appropriate medical or health care providers if you have any concerns about whether the movements are suitable for you, especially if you are dealing with an illness or injury, are pregnant, or have other health, balance or mobility issues.

New tracks tagged #Assessment