Philip Jones QC and Gareth Tilley are acting for HMRC in HMRC v IGE USA Investments Ltd, a claim arising from the Revenue’s contention that it has rescinded tax settlements with the UK Subgroup of the US conglomerate worth upwards of £650m. The trial is to take place in late 2021. An interlocutory decision of Zacaroli J reported at [2020] EWHC 2121 (Ch) permitting the Claimants to amend to allege fraud is currently on appeal to the Court of Appeal raising the question of what if any limitation period applies to equitable claims for rescission on the basis of fraudulent misrepresentation.