‘My clients range from HNWs and their businesses to large corporates. They include celebrities, sports stars and senior professionals,’ says Lee Ellis, a partner in the tax litigation and investigations department at litigation behemoth Stewarts.
‘All are looking for expert but practical advice,’ he adds. But what does this entail? ‘The communication of what can be complex issues in a way that allows them to assess matters from all angles and move forward in a collaborative manner.’
Ellis has insider knowledge of HMRC, having previously been a senior lawyer and manager with HMRC Solicitor’s Office, handling the largest and most complex tax litigation and advisory work, including budget and finance bills. Today he tells us he has ‘particular specialisms in direct tax issues which engage issues of public law, EU law and international tax treaties.’
Recent cases upon which he has advised include acting for various groups of investors in claims seeking over £100 million in redress relating to failed investments said to have had significant tax benefits, and acting for individuals to resolve complex tax disputes or issues with HMRC.
Ellis has helped establish real momentum for the department. ‘From a standing start in 2014, the department is now working on projects with a combined worth of approximately half a billion pounds across a full range of tax disputes,’ he tells us. The team has also grown rapidly from two partners to five.
How is the job changing today? Ellis points to ‘an increasingly powerful and proactive HMRC with a remit to tackle avoidance and increase yield’. He tells us that this ‘will undoubtedly include increased challenges to what may be the long-held view on certain technical tax issues.’ He also notes that there is ‘continued public scrutiny of the tax affairs of HNWs.’
And what would he change about the current taxation landscape? ‘The tax code itself is unnecessarily complex and too driven by political considerations of the Government of the day,’ he says, adding that ‘the balance between HMRC powers and the circumstances and timeframes within which they can be used is balanced far too in favour of HMRC.’
So what separates the great from the good in this field? Ellis says it’s ‘the ability to understand what the client wants to achieve, and then explain complex issues of tax law; so that the client is empowered and informed to decide how to proceed from a position of strength.’
Outside of his work, Ellis enjoys sport, travel and taking photographs in the Peak District.