John Cassidy

John Cassidy

Partner, Head of Tax Resolutions
London

I am Head of the Tax Resolutions team with over 30 years' experience in tax.

I regularly write and lecture on tax topics. I have written chapters on tax investigations in technical books as well as numerous articles for the professional, national and local press. I also lecture at tax conferences in the UK and overseas on investigations, disclosures, HMRC's powers and taxpayer rights.

What I Do

  • Tax investigations and enquiries
  • Voluntary disclosures to HMRC
  • Contractual Disclosure Facility cases involving suspected tax fraud – also known as COP9 investigations
  • Protect clients' rights and ensure that HMRC follows the rules
  • Worldwide Disclosure Facility
  • Code of Practice 8 enquiries
  • Negotiate settlements with HMRC
  • Penalty mitigation and suspension of penalties
  • Discovery assessments, powers to issue them and relevant time limits
  • Appeals against penalties, discovery assessments and other HMRC decisions, all the way to the First Tier Tax Tribunal, if necessary
  • Common Reporting Standard
  • Requirement to correct and failure to correct penalties
  • Technical dispute resolution and other HMRC challenges under Self-Assessment
  • Representations to HMRC/the tax tribunal
  • Tax avoidance disputes
  • Residence and domicile enquiries and disputes
  • Professional negligence cases concerning tax
  • Expert witness/expert adviser in court cases
  • Corporate offence of failure to prevent the facilitation of tax evasion

My Clients

  • Taxpayers who need to make disclosures to HMRC
  • Taxpayers who have been accused of tax fraud by HMRC
  • Taxpayers who are under self-assessment enquiry
  • Individuals including high net worth individuals, the self-employed, partners and those with residence/domicile issues
  • Directors and shareholders with regard to company issues
  • Trustees, settlors or beneficiaries of offshore/UK trusts with tax issues
  • Taxpayers with overseas assets or structures that need to be reviewed from a UK tax perspective
  • Other accountants and solicitors who require specialist tax investigations support
  • Companies, including LLPs and partnerships, subject to the corporate facilitation offence

Memberships