She said the lack of full liability protection had been an issue for her, but she has started up her company nonetheless.

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"We have previously admitted full liability for the brain injury Alfie sustained at the time of his birth in March 2006, " he said.

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Antony Sumara, chief executive of the hospital, has apologised for Mrs Astbury's care and the local NHS trust has admitted full liability in separate civil proceedings.

BBC: Gillian Astbury

"The publication of these names sends a clear signal that cheating on tax is wrong and reassures people who pay their taxes - the vast majority - that there are consequences for those who refuse to tell HMRC about their full liability, " said Treasury Minister David Gauke.

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Joint and several liability means that each spouse is liable for up to the full amount of the liability, though the IRS cannot collect more than the full amount of the liability.

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While they fully understand that while they remain tax resident in a country they need to pay their full tax liability, they also believe that it is their right to decide to leave that jurisdiction if they wish.

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The company later accepted liability for the shortfall and paid the full amount.

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Generally, section 4980H(b) liability may arise because, with respect to a full-time employee who has been certified to the employer as having received an applicable premium tax credit or cost.

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But rather than commit their full resources to the crisis, they are seeking to limit their liability.

ECONOMIST: Charlemagne