Shane O'Driscoll

Corporate tax

• Research and Development (R&D) relief / disputes – advising on ongoing enquiry with HMRC;
• Corporate structuring / Earn outs;
• M&A Tax Due Diligence;
• M&A Tax / share sale;
• W v. HMRC (High court). Setting aside a tax debt / enforcement proceedings – awaiting judgment;
• Opinion on the Tax implications of a proposed settlement between two shareholders (Directors Loan; CGT on share transaction; share valuation);
• I will be appearing in the Court of Appeal with Harriet Brown in D v. HMRC – pension taxation;
• HMRC Penalty submissions ( Schedule 24 of Finance Act 2007);
• Tax treatment of legal expenses / business expense/ partnership;
• Employment related issues:
  • IR35 / off payroll;
  • Disguised Remuneration (Part 7A).

Private Client

• Will interpretation  (Benham/Ratcliffe issues);
• Inheritance Tax / Residence Nil Rate Band. Seminar for the IPW;
• IHT planning / Gifts out of income;
• Domicile opinion/ advisory;
• Opinion on tax treatment of crypto assets / domicile/ remittance issues;
• Trust advisory.

Commercial Litigation

• M v C Advising on the merits of a commercial claim (Crypto engineering and development / token equity);
• HG v. P. Representing a party in a dispute with a payment service provider
• Data Protection – advising on subject access requests / GDPR
• Advising on minority shareholder disputes;
• Advising on the implication of an auditor resignation

In addition to the above, he has performed some discreet pieces of work for other members of  chambers:

• Performing research for other members of chambers:
  • Safeguarding policy review;
  • Data Protection legislation in St Helena;
• Diverse litigation preparation / drafting of affidavits for ongoing disputes.