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Articles

Other Publications

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This is a list of most of the articles that we have written. You can click on the title of the article published in the last five years and be taken to the text of that article. These articles are reproduced with the permission of the publisher. Clicking on the publisher's name will, where there is a link, take you to the publisher's website.

NAME OF ARTICLE

PUBLICATION

DATE

Intra-United Kingdom Residence

Private Client Business

December 2015

Celtic Complexities

Tax Adviser

October 2015

Project Blue Ltd v HMRC: An Arbitrary Decision (Part 2)

Private Client Business

October 2015

Project Blue Ltd v HMRC: Constructive Abdication (Part 1)

Private Client Business

July 2015

Land Tax Lottery

Taxation

25th June 2015

The Tax Chink

Tax Journal

December 2014

L’Embarras Des Richesses

Tax Journal

December 2014

One Minute With Simon McKie

Tax Journal

November 2014

Doing Good by Stealth?

Tax Adviser

August 2014

Fair Administration?

Tax Adviser

July 2014

9m Goes West

Tax Journal

20th June 2014

Book Review:  The New Statutory Residence Test for Individuals: A Practical Guide, by Malcolm Finney and Residence: The Definition in Practice 2013/14 by Keith Gordon

Private Client Business

April 2014

Statutory Residence Test

CCH Tax News

Issue 158 - April 2014

Statutory Residence Test

Taxline

October 2013

Book Review:  The Taxation of Non-Residents and Foreign Domiciliaries 2012/13 by James Kessler QC and Trust Taxation by Emma Chamberlain and Chris Whitehouse

Private Client Business

July 2013

Second Thoughts:  An Eagerly Awaited Decision

Private Client Business

July 2013

Obscurity Remains

Trust Quarterly Review

June 2013

Futter & Pitt: the Hastings-Bass Principle

Tax Journal

31 May 2013

Examining the Scope of FA 2003 s75A

Tax Journal

17 May 2013

Growing Like Topsy

Taxation

25 April 2013

Read the Small Print

Private Client Adviser

February 2013

Opportunity Missed

Tax Adviser

February 2013

The General Anti-Abuse Rule

Private Client Yearbook

January 2013

Statutory Residence Test

Private Client Business

December 2012

Book Review:  Tax Avoidance by Rebecca Murray

Private Client Business

December 2012

The Law of Unintended Consequences

Private Client Business

December 2012

FB 2013: The Statutory Residence Test

Tax Journal

18 December 2012

Fifty Shades of Grey

Taxation

5 July 2012

Unnecessary Complication

Taxation

24 May 2012

The Philosopher’s Stone or the Emperor’s New Clothes - An Old Conundrum

Private Client Business

May 2012

Background to the Extension of the Disclosure Rules to Inheritance Tax – Part II

Private Client Business

May 2012

Is Tax Avoidance Wrong?

Church Times

27 April 2012

The Acid Test

Tax Adviser

March 2012

Disclosure of Tax Avoidance Schemes and Inheritance Tax - Part Two

Trust Quarterly Review

December 2011

The Background to the Extension of the Disclosure Rules to Inheritance Tax - Part I

Private Client Business

October 2011

Disclosure of Tax Avoidance Schemes and Inheritance Tax - Part One

Trust Quarterly Review

September 2011

Reviews - Figleaf or Shield?

Tax Adviser

13 May 2011

Insurance Valuations

Private Client Business

May 2011

Book Review: Hamilton on Tax Appeals

Taxation

7 April 2011

A Changed Climate

Taxation

3 March 2011

Unsettled Trust

Tax Adviser

January 2011

Gone Phishing

Taxation

11 November 2010

Please Listen

Taxation

14 October 2010

A Settled Purpose - Inheritance Tax Planning Through Trusts

Taxline Tax Planning 2010/2011

October 2010

Cider Insider

Taxation

9 September 2010

Book Review: McCutcheon on Inheritance Tax

Private Client Business

May 2010

Book Review: McCutcheon on Inheritance Tax

Taxation

4 March 2010

Expert Witnesses and Taxation

Private Client Business

March 2010

Tax Trap: The Sections 80 and 82 Anomaly

Private Client Business

January 2010

A Permanent Fog

Tax Adviser

December 2009

Bring in an Expert

Taxation

19 November 2009

Blind Guides: The Professional Trustee Deemed Residence Rule - A Critique of HMRCs Guidance - Issue 6

Private Client Business

November 2009

A Detailed Examination

Taxation

22 October 2009

Prodigal Sons - The Problem and the Plan

Tax Adviser

September 2009

Meeting Points from LexisNexis Private Client Tax Conference 26 February 2009

Taxation

18 June 2009

Case Note: Underwood v HMRC "A Dark Wood Where the Straight Way was Lost" - Issue 3

Private Client Business

May 2009

Meeting Points from IBC Tax Planning for Non Domiciliaries Conference 26 November 2008

Taxation

12 March 2009

The Interaction of Entrepreneurs Relief with Other Reliefs from Capital Gains Tax

Private Client Business

02 January 2009

No Surrender

Trust Quarterly Review

01 January 2009

Case Note: Underwood v HMRC : Mysterium sub Silua Part 2

Private Client Business

01 November 2008

Tolleys Tax Planning for Landed Estates Meeting Points Part 2

Taxation

25 September 2008

Tolleys Tax Planning for Landed Estates Meeting Points Part 1

Taxation

11 September 2008

Case Note: Underwood v HMRC : Mysterium sub Silua Part I

Private Client Business

01 September 2008

Alien Entanglements

Taxation

28 August 2008

Avoiding Our International Obligations?

Tax Adviser

May 2008

Squeezing the Pips Until the Rich Depart

Taxation

24 April 2008

Diminished Returns

Tax Adviser

April 2008

Redo from Start

Taxation

27 March 2008

Del’s Darling

Taxation

13 March 2008

Trustee Residence: Bring Back King Log

Private Client Business

01 February 2008

The Pre-Budget Report: All Change

Private Client Business

01 January 2008

Should Humpty Dumpty Be Your Guide?

Private Client Business

03 December 2007

Trust Business Turned Away - Surely Some Mistake?

Tax Adviser

December 2007

Humpty Dumpty Tax

Taxation

30 August 2007

A Nelsonian Eye

Taxation

10 May 2007

A Costly Burden

Taxation

09 November 2006

Pecuniae Obodiunt Omnia

Private Client Business

07 November 2006

Suggestio Falsi: A Commentary on the Revised Disclosure Regime for Direct Taxes

Taxation

01 November 2006

After BMBF

Taxation

12 January 2006

The Ramsay Principle and Capital Loss Schemes

Private Client Business

06 January 2006

Conference Meeting Points

Taxation

16 September 2004

Letter to the Editor

Taxation

05 August 2004

New Disclosure Duties

Elderly Client Adviser

29 July 2004

Expensive Compliance Burden on Tax Advisers

Private Client Business

01 June 2004

Big Brother Forces a Confidence I

Taxation

13 May 2004

Case Note: Jerome v Kelly: The Ontological Argument for the Existence of a Disposal

Private Client Business

01 April 2004

Quis Custodiet Ipsos Custodes?

Tax Journal

07 April 2003

Casebook: Stamping Down on Duty

Taxation

06 March 2003

Home is where the hurt is

Private Client Business

01 December 2002

Jerome v Kelly

Private Client Business

01 September 2002

Conference Report: CGT Planning

Tax Journal

05 August 2002

CGT - Gains for the Taxpayer

Private Client Business

01 August 2002

Wherever I lay my hat

Tax Journal

15 July 2002

Practical Points: Domicile

Taxline

01 June 2002

Conference Report: Property Tax

Tax Journal

13 May 2002

Tapering to a Simple Point

Private Client Business

01 March 2002

Conference Review: Onshore and Offshore Tax Planning for the Wealthy

Tax Journal

21 January 2002

Home is Where the Hurt Is

TAXline Tax Planning

2002

Stamp Duty: Restricting Ramsay?

Taxation

13 December 2001

Conference Review: IBC Insurance for Tax Planning Conference

Tax Journal

26 November 2001

It's Criminal

Taxation

01 November 2001

Conference Review: Stamped With The Mark of Authority

Tax Journal

16 July 2001

Stamp Duty: The Up and Coming Tax Part II

Taxation

07 March 2001

For Heaven's Sake, Just Leave Us Alone

Tax Journal

05 March 2001

Stamp Duty: The Up and Coming Tax Part I

Taxation

01 March 2001

Practical Points: IHT and Land Sold Within Three Years of Death

Taxline

01 February 2001

Practical Points: CGT Taper Relief Traps

Taxline

01 January 2001

InheritanceTax - The Ageing Rottweiler

TAXline Tax Planning

2001

The Deferred Lease Scheme Post-Ingram - Having Your Cake and Eating It

Private Client Business

01 December 2000

Conference Review: Keyhaven Offshore Tax Planning and International Tax Planning

Tax Journal

02 October 2000

Practical Points: Stamp Duty and Connected Persons

Taxline

01 September  2000

Finance Bill Capital Gains Tax Anti-avoidance Provisions

Private Client Business

07 July 2000

CGT: Cooper v Billingham - Purposively Blind (Revisited)

Private Client Business

01 June 2000

Towards a Better Tax System

Tax Technical Releases

01 May 2000

Traditional Innovation - Capital Tax Planning in 2000

Tax Journal

12 April 2000

A common cause

Accountancy Age

20 March 2000

Ambiguities in 'Ambiguity'

Tax Journal

28 February 2000

Trust and Tax 2000

Tax Journal

24 February 2000

Shock "Cash for Legislation" Revelations

Tax Journal

10 January 2000

Taper Relief Planning and Traps

TAXline Planning Review

2000

Towards a Better Tax System

The Faculty of Taxation

2000

Cooper v. Billingham: Purposively Blind

Private Client Business

09 November 1999

Abusing the Tax Raising Power

Private Client Business

01 September 1999

Technical Briefings: Trust Losses - Proposed New Anti Avoidance Measure

Taxline

01 July 1999

Practical Points: Tax Planning for Non Domiciled Individuals

Taxline

01 May 1999

Comment: Camouflaged Crackdown

Taxation

11 March 1999

Trust Losses

TAXline Tax Review

1999

IBC Conference: Meeting Points

Taxation

10 December 1998

Income Tax Anniversary: Descent Into the Pitt

Tax Journal

07 December 1998

Anti Avoidance: Don't Walk Behind Elephants

Tax Journal

16 November 1998

CGT: Aspects of Taper Relief

Private Client Business

01 September 1998

CGT: The New EIS - Brown Man Speaks with Forked Tongue

Private Client Business

01 July 1998

Tax Incentives and Venture Capital

Taxline

01 May 1998

CGT: Reinvestment Relief on Minority Shareholdings

Private Client Business

01 March 1998

Private Clients: Millennial "Homme d' Affaires

Tax Journal

16 February 1998

General Anti Avoidance Rule - What Are We Going To Do About It?

Tax Journal

02 February 1998

CGT Reinvestment Relief: Sharing out Relief - II

Taxation

29 January 1998

CGT Reinvestment Relief: Sharing out Relief - I

Taxation

22 January 1998

Mergers & Acquisitions: Individual Considerations

Tax Journal

03 November 1997

Letter to the Editor

Tax Journal

21 July 1997

Plumbly v Spencer

Tax Journal

06 March 1997

Why Employ A Chartered Accountant to do Tax Work?

Taxline

01 February 1997

The Tax Rewrite Project

TAXline Tax Technical Review

1997

The Lawless IR?

Tax Journal

19 December 1996

Budget 1996 Special: Pundit's Prophecies

Tax Journal

21 November 1996

Feedback: Purposive Legislation - A Road to Ruin

Taxation

03 October 1996

The IHT and Trusts Sub Committee

Taxline

01 October 1996

Fiscal Policy: Out of Control

Tax Journal

30 May 1996

Taxline Technical Review 1996/1997

TAXline Tax Technical Review

1996

Budget 1995 Predictions: I See A Tall Dark Man in Desert Boots

Tax Journal

16 November 1995

Purposive Legislation

Taxline

01 September 1995

Readers Forum: Loose Ends - Offshore Trust Compliance

Taxation

17 August 1995

Correspondence - Black Economy

Tax Journal

27 July 1995

Information Sheet: ICAEW Tax Faculty AGM

Taxline

01 June 1995

CGT Reinvestment Relief: Dependent on IR Goodwill

Taxation

09 February 1995

Reinvestment Relief

TAXline Tax Technical Review

1995

IR Statement: CGT - Reinvestment Relief

Private Client Business

01 July 1994

Trusts: Reinvestment Relief - Availability to Trustees of Settlements

Taxline

01 March 1994

Finance Bill 1994: Reinvestment Relief

Taxline

01 February 1994

Reinvestment Relief: Settled Reinvestment

Taxation Practitioner

01 December 1993

Reinvestment Relief: Planning for Reinvestment

Taxation

18 November 1993

Reinvestment Relief: Hidden Mantraps

Taxation

11 November 1993

CGT: Roll Over and Beg

Taxation

15 July 1993

CGT: New Roll Over Relief

Taxline

01 July 1993

IHT Proposals

Taxation Practitioner

01 May 1993

Foreign Affairs: Section 13 - Fatally Flawed?

Private Client Business

01 April 1993

IHT: Deed of Variation in Relation to Pre 10 March 1992 Deaths

Taxline

01 March 1993

Roll-Over and Retirement Reliefs

TAXline Tax Technical Review

1993

CGT: Non-Resident Trusts

Taxline

01 November 1992

Practice Development: Auditing Companies - Implications for the Tax Based Practice

Taxation Practitioner

01 August 1992

Estate Planning: The Ramifications of Budget 1992

Taxation

28 May 1992

Pre-Budget Tax Planning for Settlements

Taxation Practitioner

01 February 1992

Inheritance Tax

TAXline Tax Technical Review

1992

Settlements: - A Compendium of Anomalies - III

Taxation

31 October 1991

Settlements: - A Compendium of Anomalies - II

Taxation

24 October 1991

Settlements: - A Compendium of Anomalies - I

Taxation

17 October 1991

Not so Simple

Taxation

02 November 1989

Sales of Private Trading Companies

Taxation

07 September 1989

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