After Chan failed to respond within a month, IRD initiated legal proceedings to recover the overdue taxes in April, 2010. Chan argued he had learned about the tax demand only from press reports and on the basis of that argument, sought extension of the tax assessment deadline.

The Court of First Instance ruled in favor of Chan's appeal, but the Court of Appeal reversed the decision, taking the view that taxpayers should be held responsible for keeping their addresses current.

The Court of Appeal then rejected Chan's application to take the case to the CFA, leaving Chan with his last resort to seek permission directly from the CFA.

Chan did not turn up in person at the Tuesday hearing, which took the three judges of the CFA just over an hour to dismiss unanimously Chan's application for leave to appeal. Reasons will be given at a later date.

Both sides provided little in the way of new information. Chan's counsel argued IRD wrongly assumed that tax notices were forwarded to Chan, possibly due to a "system breakdown", but the government insisted that the duty to provide a valid address rests with Chan.

The loss of the last battle meant Chan was presented immediately with an overdue profits tax demand, amounting to HK$347,413,481, including HK$17.17 million in late fees. The IRD was likely to charge an extra 10 percent late charge on top of the outstanding bill.

There is another bill sitting on Chan's desk. Chinachem Charitable Foundation, which was granted Wang's legacy, was awarded HK$230 million in court costs from Chan. The foundation had threatened to have Chan declared bankrupt, and have his assets liquidated to acquire the money.

The combined overdue payment of around HK$500 million has proven a headache for Chan. He managed to recover HK$380 million from a sale of a site on Bowen Road, but the sale was quickly frozen by IRD to cover the overdue taxes. Chinachem may still have to dig further into Chan's assets to regain its money.

According to Chan's disclosure to the court filed in May, he should still have HK$230-million worth of assets to dispose after the land sale. Though it was noteworthy that Chan had to withdraw HK$700,000 from the frozen account to pay his lawyers and counsel for the CFA hearing on Tuesday.

(HK Edition 11/21/2012 page1)