Lawyers used to practising in US district courts may be surprised to see that things are done differently in the national tax court. In an interview at the court in Washington DC, Chief Judge John Colvin explains to Erin Kelechava that the tax court places a greater emphasis on pre-trial procedures in the hope of achieving a more efficient resolution of the case on the merits.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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