Owen, Christopher: - Offshore Survey – April 2010

  • BVI brings new legislation into force
    • 1 February 2010, the Insurance Act 2008, to replace the Insurance
      Act 1994, and the Insurance Regulations 2009, which were gazetted on 22
      December 2009 to replace the Insurance Regulations 1995, were brought into
      force.The Act will have the effect of repealing and replacing the current
      legislative structure and will implement a new regime for the licensing,
      administration and supervision of insurance businesses in the BVI. Some of
      the more significant changes brought about by the Act include the
      introduction of multiple classes of insurance licences, new provisions for
      the regulation and supervision of insurance managers, intermediaries and
      loss adjusters, and reporting duties of insurance managers. The Act will
      also ensure full compliance with the International Association of
      Insurance Supervisors’ Core Principles. The BVI Financial Services
      Commission (FSC) issued the Regulatory Code 2009 on the same date. The
      Code contains detailed requirements that support the general framework
      established by the primary financial services legislation and will affect
      the operations of service providers licensed in the British Virgin Islands
      as banks, trust companies, company managers, insurers and money service
      businesses. A Financing and Money Servic es Act 2009 (FMSA) also came into
      force on 31 March. The FMSA introduces a regime for the licensing,
      regulation and supervision of financing and money services business
      carried out from or within the BVI, together with criminal offences for
      breach or non- compliance. The FMSA brings the BVI into full compliance
      with Recommendation 23 of the Financial Action Task Force. The FSC
      announced, on 5 January, the establishment of a focus group to review and
      revise existing IP laws. This is to make “recommendations for legislative
      revision that are in concert with recent developments in the field and
      industry”. The eight-member focus group includes three Queen’s Counsel and
      the FSC’s director of corporate affairs, who is also the registrar of
      trademarks and patents. It is expected to complete its work by 31 December

  • ECOFIN adopts mutual tax assistance directives
    • 16 March 2010, the European Council of Finance
      Ministers (ECOFIN) adopted directives on mutual assistance for the
      recovery of taxes. The main objective is to meet the needs of member
      states in respect of the recovery of taxes by overhauling Directive
      76/308, which has been the basis on which member states have engaged in
      mutual assistance since 1976.”National provisions on tax recovery are
      limited in scope to national territories, and fraudsters have taken
      advantage of this to organise insolvencies in member states where they
      have debts,” said a statement issued by ECOFIN. “Member states therefore
      increasingly request the assistance of other member states to recover
      taxes, but existing provisions have only allowed a small proportion of
      debts to be recovered.” According to the statement, the draft directive is
      designed to provide for an improved assistance system, with rules that are
      easier to apply, including as regards information held by banks and other
      financial institutions. It provides for more flexible conditions for
      requesting assistance and requires information to be exchanged
      spontaneously.With regard to other tax matters, the Council also agreed on
      a general approach, pending the opinion of the European Parliament, on a
      draft directive aimed at simplifying value-added tax (VAT) invoicing
      requirements, in particular relating to electronic invoicing. At an
      earlier ECOFIN meeting on 19 January, European finance ministers had
      elected to back down from a multi-pronged bid to force Austria and
      Luxembourg to open up banking secrecy laws. The decision followed a
      warning by Luxembourg’s Finance Minister Luc Frieden that EU partners were
      wasting their time trying to force him into an all-encompassing accord
      because tax matters are reserved for member states. As a result, ECOFIN
      did not to proceed with a related directive on administrative cooperation
      in the field of direct taxes or on the major proposals that form the
      anti-tax evasion and tax governance package supported by the Spanish EU
      presidency. Outgoing EU taxation commissioner Laszlo Kovacs said there
      were “five delicate taxation issues on the agenda” which were seen by most
      backers as an integrated package. But, “there was an agreement that we can
      split the package, in order to make faster progress,” he said.

  • Hong Kong signs tax treaties with Netherlands and Brunei
    • 22 March 2010, Hong Kong and The
      Netherlands signed a new treaty to avoid double taxation and to prevent
      tax evasion. It was signed by Hong Kong Secretary for Financial Services
      and the Treasury K.C. Chan and Dutch Finance Minister Jan Kees de Jager
      during the latter’s visit to China.The treaty calls for significantly
      lower withholding tax rates on passive income, including dividends and
      royalties. For dividends, a withholding tax rate of 0% – instead of the
      15% rate currently applicable in the Netherlands in absence of a treaty –
      will apply to dividends received by qualifying persons holding at least
      10% of the share capital of the paying companies. The 0% rate will also
      apply to dividends received by banks and insurance companies, pension
      funds, headquarters companies, and certain other qualifying entities. A
      withholding tax rate of 10% will apply to other dividends. Hong Kong does
      not levy withholding tax on dividends.No source taxation will apply to
      interest payments. Neither country levies withholding tax on interest
      based on domestic legislation. For royalties, Hong Kong has agreed to
      limit its withholding tax to 3%.The treaty does not include specific
      beneficial ownership or limitation on benefits clauses, but the treaty and
      protocol do contain provisions that would allow the competent tax
      authorities to determine whether a claimant would qualify for the
      favourable dividend treatment as a headquarters company or other company
      that does not have as its main purpose or one of its main purposes
      obtaining treaty benefits.Another noteworthy treaty clause is article 28,
      which states that the treaty may be extended, either in its entirety or
      with any necessary modifications, to either or both of the countries of
      the Netherlands Antilles and Aruba – or the legal successor of either or
      both of these countries – if the country concerned imposes taxes
      substantially similar in character to those to which the agreement
      applies.The treaty must be ratified both in the Netherlands and in Hong
      Kong before it can enter into force. The provisions of the treaty will
      have effect in Hong Kong, regarding Hong Kong tax, for any year of
      assessment beginning on or after 1 April 2011; and in the Netherlands,
      regarding Netherlands tax, for any tax years and periods beginning on or
      after 1 January 2011.Hong Kong also signed a tax treaty and protocol with
      Brunei on 20 March in Bandar Seri Begawan. The treaty was signed by Brunei
      Minister of Finance II Abdul Rahman bin Ibrahim and Hong Kong Financial
      Secretary John Tsang, and will enter into force 30 days after the parties
      exchange instruments of ratification.The first treaty between the
      countries, it provides that dividends will be taxable only in the country
      of the beneficial owner’s residence. Interest will be subject to a maximum
      tax rate of 5% if any bank or financial institution receives the interest,
      and 10% in all other cases. Royalties will be taxable at a maximum
      withholding tax rate of 5%, and technical assistance fees will be subject
      to a maximum tax rate of 15%.Hong Kong concluded negotiations with
      Liechtenstein on 12 March for a new tax treaty in accordance with the OECD
      model. The agreement will be signed when approved by the respective
      governments and will enter into force upon conclusion of ratification
      procedures.The Hong Kong government also announced, on 12 March, that the
      Inland Revenue (Amendment) Ordinance 2010 and Inland Revenue (Disclosure
      of Information) Rules, which passed on 6 January 2010, had came into
      force. Together they enable Hong Kong to enter into tax treaties in line
      with the OECD exchange of information article.In addition to The
      Netherlands, Brunei and Liechtenstein, Hong Kong has concluded new
      agreements incorporating the OECD exchange of information article with
      Austria, France, Hungary, Indonesia and Ireland. It is also negotiating
      with existing treaty partners to upgrade exchange of information articles
      to the new version.

  • HSBC admits Swiss data theft affects 24,000 accounts
    • 11 March 2010, Europe’s biggest bank HSBC said
      that a theft of data by a former employee affected up to 24,000 Swiss
      client accounts. The bank had previously said “less than 10 clients” were
      affected after a former employee stole client data from the bank which he
      handed over to French tax authorities.”The theft, which was perpetrated by
      a former IT employee about three years ago, involves approximately 15,000
      existing clients who had accounts with the bank in Switzerland before
      October 2006,” HSBC said in a statement. A further 9,000 accounts that had
      been closed in the past were also affected. These accounts often were not
      big enough to be eligible for private banking services, the bank said. It
      has 100,000 clients in Switzerland.HSBC “unreservedly apologised” to
      clients for the threat to their privacy, but said Swiss authorities would
      not support the use of the stolen data to answer requests from foreign
      authorities about tax issues. The stolen client information is limited to
      accounts in Switzerland, excluding ex-HSBC Guyerzeller accounts.The Swiss
      regulator, FINMA, was investigating how “a data theft to this extent could
      have happened” and whether the organisational and technical measures
      implemented by HSBC since the theft to prevent such incidents complied
      with legal requirements.

  • Liechtenstein bank to appeal ruling in tax evader case
    • 8 February 2010, Fiduco Treuhand AG, a former
      subsidiary of Liechtenstein’s LGT Bank, announced that it will appeal a
      February ruling by the Liechtenstein district court (Landgericht) awarding
      a former client €7.3 million in damages.German national Elmer Schulte
      filed a lawsuit accusing the bank of negligence for its failure to warn
      him that data revealing his hidden assets had been compromised when former
      LGT employee Heinrich Kieber stole data on account holders and sold it to
      German, and other national, authorities. Schulte was convicted of tax
      evasion in 2008 in a German court, reportedly receiving a €7.3 million
      fine in lieu of prison time. According to press reports, Schulte is also
      planning to appeal the Landgericht ruling, arguing that the award is too
      low and that his three other claims alleging that he received bad advice
      from the bank should not have been dismissed. Schulte alleges that LGT
      Treuhand bank employees invested his assets in so-called black funds in
      tax havens such as the Cayman Islands and Luxembourg without adequately
      advising him. Both appeals will go to the Liechtenstein Supreme Court
      (Oberster Gerichtshof).

  • Luxembourg approves 20 tax treaties and protocols
    • 17 March 2010, the Luxembourg Chamber of
      Deputies adopted a first reading draft Law ratifying Luxembourg’s 20
      pending tax treaties and tax treaty protocols that include the OECD
      exchange of information article. Ratification will be completed after the
      draft law is adopted by the Chamber of Deputies in a second reading and is
      signed by Grand Duke Henri. The Law will ratify new tax treaties with:
      Bahrain, signed 6 May 2000; Armenia, signed 23 June 2009; Qatar, signed 3
      July 2009; Monaco, signed 27 July 2009; and Liechtenstein, signed 26
      August 2009. The Law will also ratify protocols to existing tax treaties:
      1996 Luxembourg-US tax treaty; 1968 Luxembourg-Netherlands tax treaty;
      1958 France-Luxembourg tax treaty; 1980 Denmark-Luxembourg tax treaty;
      1982 Finland-Luxembourg tax treaty; 1967 Luxembourg-UK tax treaty; 1962
      Austria-Luxembourg tax treaty; 1983 Luxembourg-Norway tax treaty; 1970
      Belgium-Luxembourg tax treaty; 1993 Luxembourg-Switzerland tax treaty;
      1999 Iceland-Luxembourg tax treaty; 2003 Luxembourg-Turkey tax treaty;
      2001 Luxembourg-Mexico tax treaty; 1986 Luxembourg-Spain tax treaty; and
      1958 Germany-Luxembourg tax treaty.

  • Mauritius orders check on “round-tripping”
    • 19 January 2010, the Mauritius Financial Services
      Commission said it had imposed a stringent set of conditions on
      Mauritius-based companies investing in India in a bid to allay concerns
      about “round-tripping” of funds. It also warned that licences of entities
      investing in India would be revoked if they source funds from
      India.Mauritius is the top source of foreign direct investment (FDI)
      flowing into India. During the first seven months of the current financial
      year, nearly $8 billion of the $18 billion FDI flowing into India came
      from Mauritius. The India-Mauritius tax treaty provides capital gains
      exemption to all Mauritius-based investors investing in India. The Indian
      government has been pushing for a renegotiation of the treaty for many
      years, but Mauritius has consistently refused to do so. An annual audit of
      Mauritius-based entities investing in India has now been made mandatory,
      said Milan Meetrabhan, chief executive of the Financial Services
      Commission of Mauritius. The Indian side has been apprised of the steps
      taken to check round-tripping and Mauritius hopes that this will take care
      of the concerns about tax evasion.A Mauritian team headed by Dr Rama
      Sithanen, vice prime minister and minister of finance, met Indian finance
      minister Pranab Mukherjee. “There are concerns and we are addressing them.
      Mauritius is not a tax haven,” Sithanen said. “There are a number of other
      countries with more attractive tax treaties with India, but so much
      investment is not flowing through them. Mauritius is preferred because we
      have a transparent regulatory system and a sound financial sector.”
      Sithanen added that India and Mauritius had already formed a joint working
      group to look into the ways of improving the information flow between
      them. Mauritius remained open to any suggestions to improve the financial
      reporting between two nations.

  • Obama signs HIRE-FATCA Bill into law
    • 17 March 2010, President Obama signed into law the Hiring Incentives to Restore Employment (HIRE) Act of 2010, which raises $8.7 billion through new withholding rules and other enforcement measures from the Foreign Account Tax Compliance Act (FATCA) in order to fund $13 billion in tax incentives for companies hiring new workers.The law will essentially present foreign financial firms with the choice of entering into agreements with the IRS to provide information about their US accountholders or becoming subject to 30-percent withholding tax. The reach of the legislation goes beyond traditional financial institutions and covers virtually every type of foreign financial institution (FFI), including hedge funds, private equity funds and typical offshore securitisation vehicles that hold US assets and issue their own equity and debt securities, such as collateralised debt obligation issuers. The provisions in the “FACTA” element of the Act will:
      Impose a 30% tax withholding on payments either
      to foreign banks and trusts that fail to identify US accounts and their
      owners and assets to the IRS, or to foreign corporations that do not
      supply the name, address, and tax identification number of any US
      individual with at least 10% ownership in the firm (effective for
      payments made after 31 December 2012, with some exceptions for
      grandfathered agreements);
      Extend bearer-bond tax penalties to any such
      bonds marketed to offshore investors, and prevent the US government from
      issuing bearer b onds (effective two years after the date of enactment);
      Impose penalties as high as $50,000 on US
      taxpayers who own at least $50,000 in offshore accounts or assets but
      fail to report the accounts on their annual income tax return (effective
      for tax years beginning after the date of enactment);
      Levy a 40% penalty on the amount of any
      understatement attributed to undisclosed foreign assets (effective for
      tax years after the date of enactment);
      Extend to six years the statute of limitations
      for “substantial” omissions – exceeding $5,000 and 25% of reported
      income – derived from offshore assets (effective for returns filed after
      the date of enactment or for any return filed on or before that date if
      the section 6501 assessment period for that return has not expired as of
      the date of enactment);
      Require shareholders in passive foreign
      investment companies to file annual returns (effective on enactment);
      Oblige financial firms to file withholding tax
      returns electronically, even if they file fewer than 250 returns
      annually (effective for returns due after the date of enactment);
      Codify Treasury regulations that treat foreign
      trusts as having US beneficiaries if any current, future or contingent
      beneficiary is a US person;
      Allow the Treasury Department to presume that a
      foreign trust has US beneficiaries if a US person directly or indirectly
      transfers property to the trust (effective for transfers of property
      after the date of enactment);
      Establish a $10,000 minimum failure-to-file
      penalty for some foreign trust-related information returns (effective
      for notices and returns due after 31 December 2009); and
      Subject dividend equivalent payments included in notional principal contracts and paid to overseas corporations to the same 30% withholding tax levied on dividends paid to foreign investors (effective for payments made on or after 180 days after enactment).
      FATCA as included in the HIRE Act omits the language
      that would have required tax or investment advisors to disclose the
      identities of any clients that they assist in buying offshore assets, as
      well as the assets purchased.

  • Swiss Federal Council specifies measures to combat tax evasion
    • 24 February 2010, the Federal Council
      laid out measures for implementing its strategy, agreed last December, of
      preserving the integrity of its financial centre by preventing the flow of
      undeclared funds from foreign countries into Swiss banks.To achieve
      clarity and legal security, it wished to push ahead with the
      regularisation of undeclared assets whilst at the same time ensuring that
      privacy is safeguarded. “The Federal Council is against attracting
      undeclared funds from overseas. In order to prevent new, undeclared funds
      from coming to Switzerland, the Federal Department of Finance (FDF) will
      draw up various solutions,” it said. It has also instructed the FDF to
      continue to implement the new administrative assistance policy. Since 13
      March 2009, Switzerland has been offering international administrative
      assistance in accordance with the OECD standard, and no longer makes a
      distinction in relation to foreign countries between tax fraud and tax
      evasion in the case of corresponding applications. In the meantime, the
      Federal Council said Switzerland has negotiated tax treaties with 18
      countries on the basis of the OECD standard. The onus was now on
      parliament to ratify them. The Council of States would address the first
      five treaties in the spring session. The statement noted that: “The
      Federal Council continues to reject the automatic exchange of information
      in terms of laying bare every detail of citizens’ lives.”

  • Switzerland and US agree Protocol to amend UBS Agreement
    • 31 March 2010, the Swiss Federal
      Council and US government approved an amending protocol to revise the UBS
      Request Agreement. This was to remedy the shortcomings pointed out in the
      Federal Administrative Court’s judgment of 27 January and ensure that
      Switzerland was able to fulfill its obligations under international law
      that it entered into with the original agreement.The amending protocol
      raises the treaty request agreement of 19 August 2009 to the same level as
      the bilateral tax treaty such that the UBS Agreement now takes precedence
      over the older and more general treaty, and permits Switzerland to provide
      treaty assistance in cases not only of tax fraud, but also of continued
      and serious tax evasion. By signing the UBS Agreement last August,
      Switzerland undertook to process the US request for treaty assistance – by
      issuing around 4,450 final decisions – within a year. But the Federal
      Administrative Court ruled that the agreement’s more liberal
      interpretation of “tax fraud and the like” was insufficient to change the
      meaning of the current Swiss-US tax treaty. As a result, it prohibited the
      government from disclosing information not covered by the current treaty’s
      allowance for disclosure of cases involving tax fraud as defined by Swiss
      law. The ruling affected approximately 4,200 of the expected disclosures.
      The Swiss government announced on 24 February that it would therefore seek
      parliamentary approval of the August agreement, which would give the
      agreement the same effect as a treaty and overcome the court’s objections.
      The new amending protocol states clearly that the UBS Agreement is not
      simply a competent authority interpretation, but constitutes an
      international agreement. Furthermore, a conflict of laws regulation
      determines that the UBS Agreement takes precedence over the bilateral
      double taxation convention and the attendant protocol in the event of any
      clash. Finally, the amending protocol lays down regulations for the
      provisional application of the revised Agreement. In cases of particular
      urgency and in order to safeguard important Swiss interests, under the
      terms of governmental and administrative organization law, the Federal
      Council may apply a treaty provisionally from the date on which it is
      signed. The Federal Council said it felt that there were compelling
      reasons to exercise this authority because the present case fulfills both
      the particular urgency and important interests conditions. Legal hearings,
      the examination of the corresponding statements and the sheer dimensions
      of the process meant that it would be impossible to complete all cases in
      parallel before the one-year deadline if application were delayed until
      after the June session of parliament. This would a risk a legal and
      sovereignty conflict with the US. The Federal Council said the provisional
      application of the revised treaty request agreement did not take the Swiss
      parliament’s decision for granted. Rather, it guaranteed that the
      agreement that is submitted to parliament could actually be implemented
      after its approval. The Federal Council would issue its dispatch on the
      acceptance of the revised treaty request agreement to parliament in April
      and had instructed the Swiss Federal Tax Administration not to hand over
      any client data to the US until the UBS Agreement has been passed by

  • Switzerland signs tax treaty with Netherlands
    • 26 February 2010, Switzerland and the Netherlands
      signed a new income tax treaty that includes Article 26 of the OECD Model
      Tax Convention on Exchange of Information and the definitions of residency
      and permanent establishment. The new agreement will replace the existing
      treaty of 1951.The percentage holding for withholding tax exemption for
      dividends has been reduced from 25% at present to 10%. This threshold
      corresponds to the minimum holding requirement based on the EU parent
      subsidiary directive. Dividend payments to pension funds will also be
      exempt from tax in the source state in future. Interest payments and
      royalties are zero-rated. The old treaty limited withholding tax on
      interest to 5%.The provision in the protocol of the old treaty for an
      upfront allocation of 10% to 20% of profits to the place of effective
      management of a company, if it had a permanent establishment in the other
      contracting state, has not been adopted in the new treaty. The new treaty
      also contains an arbitration clause if the competent authorities are
      unable to reach an agreement within three years following the commencement
      of a mutual agreement procedure.

  • UK Appeal Court rejects Gaines-Cooper claim
    • 16 February 2010, the UK Court of Appeal rejected
      an appeal by British businessman Robert Gaines-Cooper that he did not owe
      taxes because he was a non-resident, leaving him a £30 million tax bill
      for the years 1993 to 2004. It held that a taxpayer must show a “distinct
      break” from social and family ties to the UK and that spending less than
      91 days outside the country is not sufficient to establish non-residency
      status.The case involved judicial review of the earlier decision that the
      position of HM Revenue & Customs (HMRC) was contrary to the guidance
      given in leaflet IR20. Gaines-Cooper had argued he did not owe taxes in
      the UK because he has been a resident of the Seychelles since 1976. He
      justified his position with a rule that defines a non-resident as one who
      spends less than 91 days per year in the UK. The Court of Appeal confirmed
      the importance of Revenue practices and that HMRC were indeed bound by the
      terms of IR20. But it also accepted that there was an implied condition in
      IR20 that, in order for the individual in question to be treated as
      non-resident, they have to have made a distinct break with the UK by
      severing all social and family ties with the UK. And, as Gaines-Cooper was
      deemed not to have done so, he was to be treated as resident in the UK
      even after his ostensible departure in 1976. Lord Justice Alan Moses,
      writing for fellow judges Dyson and Ward LJJ, said that the correct
      interpretation of tax residency status turned on whether England had
      remained the taxpayer’s “centre of gravity of his life and interests,”
      according to the report. The 91-day rule could not establish non-resident
      status, rather it was “important only to establish whether non-resident
      status, once acquired, has been lost”. The court found that Gaines-Cooper,
      who was born in Reading in Berkshire, never meaningfully cut ties with the
      UK. He maintained a mansion at Henley-on-Thames, which the court called
      his “chief residence” and was home to his second wife and son, as well his
      collections of art and guns. Also, his son attended an English school, his
      will was drawn up under English law and he regularly attended Ascot
      racecourse. Because of these connections, the court found that
      Gaines-Cooper had failed to show the required distinct break and that his
      complaints of unfair treatment by HMRC were based on an “impossible
      construction” of the law. The fact that Gaines-Cooper had not been in the
      country for more than 91 days in any one year since 1976 made no
      difference to his status, the court said. The court said HMRC’s
      interpretation of tax residency was correct, adding that there were “ample
      grounds on which to conclude that he had been resident and ordinarily
      resident in the UK throughout [the period]”. HMRC is “fully entitled to
      look for a clear break – or a clean break – with this country before
      affording non-resident status,” the court concluded. Gaines-Cooper plans
      to appeal the case to the Supreme Court. His counsel said that HMRC was
      “playing games” with his client and mischievously reinterpreting its own
      guidance, turning it “from a sensible, practical, guide into something
      meaningless and, which is worse, a devious trap”.

  • UK Court upholds retrospective enforcement of anti-avoidance rules
    • 27 January 2010, the UK High Court
      upheld the right of HM Revenue & Customs to seek £100 million in
      income taxes from 2,500 users of an offshore tax avoidance scheme. It also
      ruled that the backdating of demands was “in the relevant circumstances
      proportionate” and did not breach human rights.In R (on the application of
      Huitson) v HMRC, Robert Huitson was a UK-resident, self-employed IT
      contractor who, before 2008, belonged to a scheme whereby his services to
      UK clients were supplied through an Isle of Man intermediary. Double
      taxation relief under the UK-Isle of Man tax treaty ensured that no UK
      income tax liability arose. The judge said that the overall effect had
      been to reduce Huitson’s tax rate to just 3.5%.The UK Finance Act 2008
      subsequently prevented this type of scheme from working, with
      retrospective effect. Huitson issued an application for judicial review,
      arguing that HMRC’s retrospective imposition of the law breached the 1998
      Human Rights Act. He emphasised that HMRC had failed to take any action
      against the sch eme before the law was changed, despite being well aware
      of it.Mr Justice Parker rejected this, upholding the 2008 Finance Act,
      which let the Revenue close the loophole retrospectively. He noted that
      the Revenue had warned the users of the tax avoidance scheme that it might
      be challenged, and said the government was entitled to change tax law
      retrospectively to quash artificial arrangements. “The tax avoidance
      scheme, if it worked, would, therefore, appear to realise every taxpayer’s
      dream of lawfully avoiding, or at least greatly reducing, income tax in
      any jurisdiction,” he said. “It is also immediately plain that the tax
      avoidance scheme, if it worked, would be singularly attractive to any
      person in the position of the claimant, that is, any resident of the UK
      who, as a self-employed person, carried on a trade or profession here.”
      Although the judge refused Huitson permission to appeal, his lawyers
      indicated that they would ask the Court of Appeal to hear the case because
      of its important general implications.

yeezy boost 350 oxford tan adidas yeezy 350 boost oxford tan release date moonrock yeezy 350 boost legit real fake adidas yezzy boost 350 pirate black moonrock restocking yeezy boost 350 moonrock raffle yeezy boost 350 moonrock 331592665172 is the adidas yeezy boost 350 turtle dove releasing again yeezy boost 350 turtle dove AQ4832 fse 082415 p se yeezy boost 350 adidas yeezy 350 boost where to buy yeezy boost 350 v2 black white adidas yeezy boost 350 pirate black adidas yeezy boost 350 v2 black white adidas yeezy boost 350 v2 blackwhite reservations open december 15 confirmed app buy black friday yeezy boost 350 v2 yeezy boost 350 v2 black white adidas yeezy boost 350 v2 official images adidas yeezy boost 350 v2 restock info adidas yeezy boost 350 v2 beluga solar red adidas yeezy boost 350 v2 beluga launches tomorrow news.23913.html yeezy boost 350 v2 black white release date adidas yeezy yeezy boost 350 v2 bw raffle store list for the black white adidas yeezy boost 350 v2 release news.26285.html adidas yeezy boost 350 v2 black white release procedure announced news.26233.html yeezy boost 350 v2 black white raffle