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Creative

Tax litigation and portfolio reconstruction

The Situation: Liechtenstein-based account with missing documentation

  • A client inherited a Liechtenstein-based account and decided to disclose it under the facility established by HMRC.
  • The documentation on the account was incomplete and the true value of the inheritance could not be established.

The Challenge: Determine how the account would have been managed

  • We were asked to develop a framework for how the account was most likely managed over the period of the missing documentation. One key objective was to separate inheritance tax and income tax liabilities.

The Resolution: Comprehensive report for use with HMRC

  • Beginning with the last available portfolio valuation, we worked back to inception, reconstructing the portfolio and its performance over the missing time period.
  • We drew up a framework for how the account was most likely managed and established key parameters which would have governed the account.
  • On the basis of our report, the client was able to segregate their tax liabilities and present a rational report to HMRC, including a consistent set of account calculations.