Dr. Jim Stewart:

That is one of the problems in that if you are a section 110 firm because you apply to Revenue, you self select. You say "we are a section 110 firm" and Revenue tells you have that status. I have not read of any case where Revenue has said to a section 110 firm "sorry you do not meet these criteria and you are no longer a section 110 firm". Having said that, I notice that there some section 110 firms that have migrated to being 25% companies. They no longer state that they are section 110 firms. This might be because they no longer meet the requirements of Revenue. I am not quite sure about it. The number of such companies is very small. I think I have come across about a handful of firms in hundreds of cases I have examined.