By Sinead O'Callaghan, partner at Cooke, Young and Keidan

It has recently been announced that HM Revenue & Customs (HMRC) will be empowered under the next Finance Bill to issue Financial Institution Notices.

Under these new rules, HMRC will be able to compel financial institutions, including banks, credit card issuers, fund managers and insurance companies, to provide disclosure in relation to their customers, without a court order or customer authorisation. 

Whilst it is worth mentioning that trusts are not financial institutions for this purpose, HMRC may try to circumvent this by issuing n...