Foo Hui Min (1) - Chosen.png

Foo Hui Min

Partner

Practice Area:

Tax

LLM, National University of Singapore
LLB (Hons), National University of Singapore
Advocate & Solicitor, Singapore

T +65 6232 0498
E huimin.foo@rajahtann.com

Hui Min has 25 years of experience as a tax counsel with the Inland Revenue Authority of Singapore. Hui Min was for more than 15 years a Director/Branch Head in the Law Division of the IRAS. Her responsibilities included reviewing legal advice, submissions and legislative amendments of tax statutes prepared by the Law Division. She also represented the Authority in civil litigation.

During her long service with the IRAS, Hui Min was lead counsel in several seminal income tax authorities decided by the Singapore Supreme Court and the tax tribunals. These include ABD Pte Ltd v Comptroller of Income Tax [2010] SGHC 107 where Andrew Phang JA comprehensively articulated the judicial tests for the capital-revenue distinction. She also argued IB v Comptroller of Income [2004] SGITBR 10, the first judicial decision to delineate the scope of section 10(1)(g) of the Income Tax Act. More recently in BML v Comptroller of Income Tax [2018] SGCA 53, Hui Min successfully persuaded the Court as to the requirements for the deduction of interest expenses, in respect of “capital employed in acquiring the income” under s 14(1)(a) of the Income Tax Act.

Hui Min also represented the Authority before the Supreme Court in several property tax and stamp duty appeals. A full list of the tax cases handled by Hui Min as lead counsel is set out below.

Before joining IRAS in 1995, Hui Min was a member of the Singapore Administrative Service where her postings included the Ministry of Finance and Prime Minister’s Office. As a Deputy Director in the Public Service Division, her portfolio included human resource policy formulation and related legislative review.

Experience / Notable Cases
Revenue Cases
  • BML v Comptroller of Income Tax [2018] SGCA 53; BML v Comptroller of Income Tax [2017] SGHC 118; BML v Comptroller of Income Tax (2017) MSTC 70-038 (also reported as GBK v Comptroller of Income Tax [2016] SGITBR 3
  • BFC Development LLP v Comptroller of Property Tax [2014] SGCA 9
  • HSBC Institutional Trust Services (Singapore) Ltd v Chief Assessor [2013] SGCA 4
  • Comptroller of Income Tax v BBO [2014] SGCA 10; Comptroller of Income Tax v BBO [2013] SGHC 74; BBO v Comptroller of Income Tax [2012] SGITBR 2
  • Lai Ling Wan (alias Lily Lai) v Commissioner of Stamp Duties [2011] SGHC 186
  • AYH v Comptroller of Income Tax [2011] SGITBR 4
  • ABD Pte Ltd v Comptroller of Income Tax; [2010] SGHC 107; [2010] 3 SLR 609;
  • Cheok Doris v Commissioner of Stamp Duties [2010] SGHC 168; Cheok Doris v Commissioner of Stamp Duties [2010] SGCA 28
  • Comptroller of Income Tax v VJ [2008] SGHC 224; VJ v Comptroller of Income Tax [2007] SGITBR 3
  • BCH Retail Investment Pte Ltd v Chief Assessor [2007] SGCA 15; BCH Retail Investment Pte Ltd v Chief Assessor [2005] SGVRB 5
  • ND v Comptroller of Income Tax [2006] SGITBR 3
  • IB v Comptroller of Income Tax [2004] SGITBR 10 (also reported as DWTH v Comptroller of Income Tax (2005) MSTC 5,347)
  • Pinetree Resort Pte Ltd v Comptroller of Income Tax 48; [2000] SGCA 48; Pinetree Resort Pte Ltd v Comptroller of Income Tax 48 [2000] SGHC 24; HU v Comptroller of Income Tax [1999] SGITBR 1
  • Singapore Airlines Ltd and another v Inland Revenue Authority of Singapore and another [1999] 2 SLR(R) 1097
  • MPD v Comptroller of Income Tax (1998) MSTC 5,249 (also reported as HS v Comptroller of Income Tax [1998] SGITBR 2)
 Memberships
  • Accredited Tax Adviser, Singapore Institute of Accredited Tax Advisers