Home Publications Articles
Title Published Publication
Private Residence Relief A matter of construction 30 November 2023
Flat Management Companies – Extensive difficulties to unlock 20 March 2023
Pre-incarnated dwellings 11 October 2022 Taxation
Lost Deposits – Wishing for the moon 14 July 2022 Tax Adviser
Inconvenient Circumstances 13 August 2020 Taxation
A Lull Before the Storm 20 April 2020 Law Society Gazette
Megxit’s Maelstrom 12 March 2020 Taxation
The Sins of the Fathers 20 February 2020 Law Society Gazette
A Higher Burden 6 February 2020 Taxation
The Fifth Money Laundering Directive: The Perils of Gold-Plating Dec 2019 Tax Adviser
Considered Revelations Aug 2019 Tax Adviser
Innocent Entanglements 11 April 2019 Taxation
Intra-United Kingdom Residence Dec 2015 Private Client Business
Celtic Complexities Oct 2015 Tax Adviser
Project Blue Ltd v HMRC: An Arbitrary Decision (Part 2) Oct 2015 Private Client Business
Project Blue Ltd v HMRC: Constructive Abdication (Part 1) Jul 2015 Private Client Business
Land Tax Lottery 25 June 2015 Taxation
The Tax Chink 19 December 2014 Tax Journal
L’Embarras Des Richesses 6 December 2014 Tax Journal
One Minute With Simon McKie 21 November 2014 Tax Journal
Doing Good by Stealth? Aug 2014 Tax Adviser
Fair Administration? Jul 2014 Tax Adviser
£9m Goes West 20 June 2014 Tax Journal
Statutory Residence 9 April 2014 CCH Tax News
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 Apr 2014 Private Client Business
Statutory Residence Test Oct 2013 Taxline
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 Jul 2013 Private Client Business
Second Thoughts:  An Eagerly Awaited Decision Jul 2013 Private Client Business
Obscurity Remains Jun 2013 Trust Quarterly Review
Futter & Pitt: the Hastings-Bass Principle 31 May 2013 Tax Journal
Examining the Scope of FA 2003 s. 75A 17 May 2013 Tax Journal
Growing Like Topsy 25 April 2013 Taxation
Read the Small Print Feb 2013 Private Client Adviser
Opportunity Missed Feb 2013 Tax Adviser
The General Anti-Abuse Rule Jan 2013 Private Client Yearbook
FB 2013: The Statutory Residence Test 18 December 2012 Tax Journal
Statutory Residence Test Dec 2012 Private Client Business
Book Review:  Tax Avoidance by Rebecca Murray Dec 2012 Private Client Business
The Law of Unintended Consequences Dec 2012 Private Client Business
Fifty Shades of Grey 5 July 2012 Taxation
Unnecessary Complication 24 May 2012 Taxation
The Philosopher’s Stone or the Emperor’s New Clothes – An Old Conundrum May 2012 Private Client Business
Background to the Extension of the Disclosure Rules to Inheritance Tax – Part II May 2012 Private Client Business
Is Tax Avoidance Wrong? 27 April 2012 Church Times
The Acid Test Mar 2012 Tax Adviser
Disclosure of Tax Avoidance Schemes and Inheritance Tax – Part Two Dec 2011 Trust Quarterly Review
The Background to the Extension of the Disclosure Rules to Inheritance Tax – Part I Oct 2011 Private Client Business
Disclosure of Tax Avoidance Schemes and Inheritance Tax – Part One Sep 2011 Trust Quarterly Review
Reviews – Figleaf or Shield? May 2011 Tax Adviser
Insurance Valuations May 2011 Private Client Business
Book Review: Hamilton on Tax Appeals 7 April 2011 Taxation
A Changed Climate 3 March 2011 Taxation
Unsettled Trust Jan 2011 Tax Adviser
Gone Phishing 11 November 2010 Taxation
Please Listen 14 October 2010 Taxation
A Settled Purpose – Inheritance Tax Planning Through Trusts Oct 2010 Taxline Tax Planning 2010/2011
Cider Insider 9 September 2010 Taxation
Book Review: McCutcheon on Inheritance Tax May 2010 Private Client Business
Book Review: McCutcheon on Inheritance Tax 4 March 2010 Taxation
Expert Witnesses and Taxation Mar 2010 Private Client Business
Tax Trap: The Sections 80 and 82 Anomaly Jan 2010 Private Client Business
A Permanent Fog Dec 2009 Tax Adviser
Bring in an Expert 19 November 2009 Taxation
Blind Guides: The Professional Trustee Deemed Residence Rule – A Critique of HMRCs Guidance – Issue 6 Nov 2009 Private Client Business
A Detailed Examination 22 October 2009 Taxation
Prodigal Sons – The Problem and the Plan Sep 2009 Tax Adviser
Meeting Points from LexisNexis Private Client Tax Conference 26 February 2009 18 June 2009 Taxation
Case Note: Underwood v HMRC “A Dark Wood Where the Straight Way was Lost” – Issue 3 May 2009 Private Client Business
Meeting Points from IBC Tax Planning for Non Domiciliaries Conference 26 November 2008 12 March 2009 Taxation
The Interaction of Entrepreneurs Relief with Other Reliefs from Capital Gains Tax 2 January 2009 Private Client Business
No Surrender 1 January 2009 Trust Quarterly Review
Case Note: Underwood v HMRC : Mysterium sub Silua Part 2 1 November 2008 Private Client Business
Tolleys Tax Planning for Landed Estates Meeting Points Part 2 25 September 2008 Taxation
Tolleys Tax Planning for Landed Estates Meeting Points Part 1 11 September 2008 Taxation
Case Note: Underwood v HMRC : Mysterium sub Silua Part I 1 September 2008 Private Client Business
Alien Entanglements 28 August 2008 Taxation
Avoiding Our International Obligations? May 2008 Tax Adviser
Squeezing the Pips Until the Rich Depart 24 April 2008 Taxation
Diminished Returns Apr 2008 Tax Adviser
Redo from Start 27 March 2008 Taxation
Del’s Darling 13 March 2008 Taxation
Trustee Residence: Bring Back King Log 1 February 2008 Private Client Business
The Pre-Budget Report: All Change 1 January 2008 Private Client Business
Should Humpty Dumpty Be Your Guide? 3 December 2007 Private Client Business
Trust Business Turned Away – Surely Some Mistake? Dec 2007 Tax Adviser
Humpty Dumpty Tax 30 August 2007 Taxation
A Nelsonian Eye 10 May 2007 Taxation
A Costly Burden 9 November 2006 Taxation
Pecuniae Obodiunt Omnia 7 November 2006 Private Client Business
Suggestio Falsi: A Commentary on the Revised Disclosure Regime for Direct Taxes 1 November 2006 Taxation
After BMBF 12 January 2006 Taxation
The Ramsay Principle and Capital Loss Schemes 6 January 2006 Private Client Business
Conference Meeting Points 16 September 2004 Taxation
Letter to the Editor 5 August 2004 Taxation
New Disclosure Duties 29 July 2004 Elderly Client Adviser
Expensive Compliance Burden on Tax Advisers 1 June 2004 Private Client Business
Big Brother Forces a Confidence I 13 May 2004 Taxation
Case Note: Jerome v Kelly: The Ontological Argument for the Existence of a Disposal 1 April 2004 Private Client Business
Quis Custodiet Ipsos Custodes? 7 April 2003 Tax Journal
Casebook: Stamping Down on Duty 6 March 2003 Taxation
Home is where the hurt is 1 December 2002 Private Client Business
Jerome v Kelly 1 September 2002 Private Client Business
Conference Report: CGT Planning 5 August 2002 Tax Journal
CGT – Gains for the Taxpayer 1 August 2002 Private Client Business
Wherever I lay my hat 15 July 2002 Tax Journal
Practical Points: Domicile 1 June 2002 Taxline
Conference Report: Property Tax 13 May 2002 Tax Journal
Tapering to a Simple Point 1 March 2002 Private Client Business
Conference Review: Onshore and Offshore Tax Planning for the Wealthy 21 January 2002 Tax Journal
Home is Where the Hurt Is 2002 TAXline Tax Planning
Stamp Duty: Restricting Ramsay? 13 December 2001 Taxation
Conference Review: IBC Insurance for Tax Planning Conference 26 November 2001 Tax Journal
It’s Criminal 1 November 2001 Taxation
Conference Review: Stamped With The Mark of Authority 16 July 2001 Tax Journal
Stamp Duty: The Up and Coming Tax Part II 7 March 2001 Taxation
For Heaven’s Sake, Just Leave Us Alone 5 March 2001 Tax Journal
Stamp Duty: The Up and Coming Tax Part I 1 March 2001 Taxation
Practical Points: IHT and Land Sold Within Three Years of Death 1 February 2001 Taxline
Practical Points: CGT Taper Relief Traps 1 January 2001 Taxline
InheritanceTax – The Ageing Rottweiler 2001 TAXline Tax Planning
The Deferred Lease Scheme Post-Ingram – Having Your Cake and Eating It 1 December 2000 Private Client Business
Conference Review: Keyhaven Offshore Tax Planning and International Tax Planning 2 October 2000 Tax Journal
Practical Points: Stamp Duty and Connected Persons 1 September 2000 Taxline
Finance Bill Capital Gains Tax Anti-avoidance Provisions 7 July 2000 Private Client Business
CGT: Cooper v Billingham – Purposively Blind (Revisited) 1 June 2000 Private Client Business
Towards a Better Tax System 1 May 2000 Tax Technical Releases
Traditional Innovation – Capital Tax Planning in 2000 12 April 2000 Tax Journal
A common cause 20 March 2000 Accountancy Age
Ambiguities in ‘Ambiguity’ 28 February 2000 Tax Journal
Trust and Tax 2000 24 February 2000 Tax Journal
Shock “Cash for Legislation” Revelations 10 January 2000 Tax Journal
Taper Relief Planning and Traps 2000 TAXline Planning Review
Towards a Better Tax System 2000 The Faculty of Taxation
Cooper v. Billingham: Purposively Blind 9 November 1999 Private Client Business
Abusing the Tax Raising Power 1 September 1999 Private Client Business
Technical Briefings: Trust Losses – Proposed New Anti Avoidance Measure 1 July 1999 Taxline
Practical Points: Tax Planning for Non Domiciled Individuals 1 May 1999 Taxline
Comment: Camouflaged Crackdown 11 March 1999 Taxation
Trust Losses 1999 TAXline Tax Review
IBC Conference: Meeting Points 10 December 1998 Taxation
Income Tax Anniversary: Descent Into the Pitt 7 December 1998 Tax Journal
Anti Avoidance: Don’t Walk Behind Elephants 16 November 1998 Tax Journal
CGT: Aspects of Taper Relief 1 September 1998 Private Client Business
CGT: The New EIS – Brown Man Speaks with Forked Tongue 1 July 1998 Private Client Business
Tax Incentives and Venture Capital 1 May 1998 Taxline
CGT: Reinvestment Relief on Minority Shareholdings 1 March 1998 Private Client Business
Private Clients: Millennial “Homme d’ Affaires 16 February 1998 Tax Journal
General Anti Avoidance Rule – What Are We Going To Do About It? 2 February 1998 Tax Journal
CGT Reinvestment Relief: Sharing out Relief – II 29 January 1998 Taxation
CGT Reinvestment Relief: Sharing out Relief – I 22 January 1998 Taxation
Mergers & Acquisitions: Individual Considerations 3 November 1997 Tax Journal
Letter to the Editor 21 July 1997 Tax Journal
Plumbly v Spencer 6 March 1997 Tax Journal
Why Employ A Chartered Accountant to do Tax Work? 1 February 1997 Taxline
The Tax Rewrite Project 1997 TAXline Tax Technical Review
The Lawless IR? 19 December 1996 Tax Journal
Budget 1996 Special: Pundit’s Prophecies 21 November 1996 Tax Journal
Feedback: Purposive Legislation – A Road to Ruin 3 October 1996 Taxation
The IHT and Trusts Sub Committee 1 October 1996 Taxline
Fiscal Policy: Out of Control 30 May 1996 Tax Journal
Taxline Technical Review 1996/1997 1996 TAXline Tax Technical Review
Reinvestment Relief 1995 TAXline Tax Technical Review
Budget 1995 Predictions: I See A Tall Dark Man in Desert Boots 16 November 1995 Tax Journal
Purposive Legislation 1 September 1995 Taxline
Readers Forum: Loose Ends – Offshore Trust Compliance 17 August 1995 Taxation
Correspondence – Black Economy 27 July 1995 Tax Journal
Information Sheet: ICAEW Tax Faculty AGM 1 June 1995 Taxline
CGT Reinvestment Relief: Dependent on IR Goodwill 9 February 1995 Taxation
IR Statement: CGT – Reinvestment Relief 1 July 1994 Private Client Business
Trusts: Reinvestment Relief – Availability to Trustees of Settlements 1 March 1994 Taxline
Finance Bill 1994: Reinvestment Relief 1 February 1994 Taxline
Reinvestment Relief: Settled Reinvestment 1 December 1993 Taxation Practitioner
Reinvestment Relief: Planning for Reinvestment 18 November 1993 Taxation
Reinvestment Relief: Hidden Mantraps 11 November 1993 Taxation
CGT: Roll Over and Beg 15 July 1993 Taxation
CGT: New Roll Over Relief 1 July 1993 Taxline
IHT Proposals 1 May 1993 Taxation Practitioner
Foreign Affairs: Section 13 – Fatally Flawed? 1 April 1993 Private Client Business
IHT: Deed of Variation in Relation to Pre 10 March 1992 Deaths 1 March 1993 Taxline
Roll-Over and Retirement Reliefs 1993 TAXline Tax Technical Review
CGT: Non-Resident Trusts 1 November 1992 Taxline
Practice Development: Auditing Companies – Implications for the Tax Based Practice 1 August 1992 Taxation Practitioner
Estate Planning: The Ramifications of Budget 1992 28 May 1992 Taxation
Pre-Budget Tax Planning for Settlements 1 February 1992 Taxation Practitioner
Inheritance Tax 1992 TAXline Tax Technical Review
Settlements: – A Compendium of Anomalies – III 31 October 1991 Taxation
Settlements: – A Compendium of Anomalies – II 24 October 1991 Taxation
Settlements: – A Compendium of Anomalies – I 17 October 1991 Taxation
Not so Simple 2 November 1989 Taxation
Sales of Private Trading Companies 7 September 1989 Taxation