After graduating in Mathematics from Durham in 2001, Hui Ling began her career in corporate finance at US investment bank Bear Stearns. There she was admitted to the Securities & Investment Institute and received a solid grounding in accounting, finance and the 100-hour working week.

She was first attracted to the tax bar under the erroneous belief that it was all numbers and Perry Mason. Albeit wrong on both counts, she was nevertheless undeterred, converting to law in 2003.

She studied the BVC part-time, whilst setting up a company in conjunction with a West London borough. Proving she had no problem keeping several balls in the air at once, Hui Ling finished Bar School in 2005 with an Outstanding. She was ranked within the top 1% of her year and won three academic awards, including first prize for Advocacy. 

Called to the bar by the Inner Temple in July 2005, Hui Ling completed pupillage at Gray’s Inn Tax Chambers in 2006. She practices in all areas of tax law, but her main interests lie in VAT, CGT, and business and corporate taxation, underpinned by writing and lecturing extensively in those areas.  Her particular love of a good argument has developed into a passion for litigating.  An equally particular aversion to losing means that she always keeps an open mind to a favourable settlement when in her clients’ best interests.

Hui Ling has served with the Officer Training Corps of the Territorial Army for 3 years. She has also run the 151-mile Marathon des Sables, rafted through the Amazon and swum the Channel in a relay, all of which she describes as “fun”, though noticeably only after the event.

Recent Advisory Work

VAT
Scope of the financial services exemption
The treatment of an exempt trader’s fees and legal costs
Reasonable excuse appeals (advice on the merits)
The constitutionality of draft VAT legislation

CGT
Consequences of the sale of shares in a private UK company to a US-listed corporation
The treatment of earn-outs and QCBs/non-QCBs
The treatment of employment-related securities
Pre- and post- 6 April 2008 planning involving offshore trusts and companies

Business/Corporate tax
Availability of group relief
Tax treatment of inter-company loans

SDLT
The availability of planning opportunities involving leases or assignments
Planning involving sub-sale relief
The treatment of transfers of land from a partner to a partnership

Other
Individual domicile and residence
Deductibility of expenditure (capital v revenue)
The POAR and GWRB regimes: estate planning involving partitioning land
Disclosure under s.20 TMA and legal advice privilege
Defending enforcement proceedings before the County Court
The treatment of a lump sum payment made under a retirement benefit scheme
The taxability of termination payments
Advising claimants in tax-related professional negligence claims

Recent Cases

Drummond v HMRC [2008] EWHC 1758(Ch) (High Court) – CGT treatment of losses arising on the disposal of second-hand life assurance policies
Underwood v HMRC [2008] EWHC 108 (Ch) (High Court; 2008) - CGT treatment of a sale and repurchase of land
Ashley v HMRC (SpC 633) (Special Commissioners; 2007) – validity of a claim for EIS relief
The Trustees of the F D Fenston Will Trusts v HMRC [2007] STC (SCD) 316 – CGT treatment of capital contributions to a US company

Publications

The Future of UK Tax: Global Developments and UK Competitiveness (Tax Journal, August 2008)
Planning gain supplement – Where are we now?  Taxation Magazine January 2008
Tax Appeals practice notes: (co-authored with Felicity Cullen; PLCTAX November 2007)
Anti-avoidance Caselaw & Tax practice notes: Direct Tax & Stamp Duty, and VAT (PLCTAX November 2007)
Contributor to Copinger and Skone James on Copyright (Taxation chapter) (Sweet & Maxwell 2007)
Abuse of Rights: The Effect of the Doctrine on VAT Planning ([2007] BTR No. 2 160)
Planning Ahead: the Future Development of Key Worker and Affordable Housing (Consilio; 27/11/2003) – government proposals on housing development and section 106 TCPA 1990

Conferences

Managing the Challenges in Tax Litigation (VAT Litigation – Redressing the Balance - LexisNexis, April 2008)
The Relationship between Tax and Accountancy (AIMS, March 2008)
Tax in Corporate Transactions (Buying and Selling) (Lowe Gordon, February 2008)
Taking a Tax Appeal (AIMS, November 2007)
Planning Reform: A Future without Planning Inquiries, s.106 Agreements – or Lawyers? (King’s College Construction Law Association, November 2007)

Professional Memberships

Member of the CIOT’s CGT and Investment Income sub-committee

Association of Tax Technicians – Associate (ATT)
Securities & Investment Institute - Associate (ASI)
Securities & Futures Authority – Qualified Representative

Member of the Revenue and Chancery Bar Associations and the VAT Practitioners Group