In Webster v R & C Commrs, the High Court refused Ms Jennifer Webster’s application to dispose of some of HMRC’s defence against a claim for breach of statutory duties by the alleged unlawful transfer of UK banking/investment data to the US tax authorities between 2016 and 2020, under the Foreign Account Tax Compliance Act 2010 (FATCA) arrangements.

Webster was born and raised in the US, and has been resident in the UK since 2000, becoming a British citizen in 2010. She renounced US citizenship in 2019, one reason being the FATCA data exchange rules.