The Decision of the Court of Session in Murray Holdings: Selling an Invention

“I had a dream about you. I invented and sold shoes that left no footprints, and you were thinking about committing a murder in a muddy area. I said that committing a murder was a bad idea, and that you should commit several murders, but I was just trying to sell more shoes.
” ― JarodContinue reading “The Decision of the Court of Session in Murray Holdings: Selling an Invention”

Thinking Fast, and Slow……About Tax.

  “You know, ‘Why? Why?’ and that was a very (again, in my way of seeing America) a very American finger-snapping question. I did something magnificent and mysterious and I got a practical ‘Why?’ And the beauty of it is that I didn’t have any ‘why’.” – Philippe Petit, Man on Wire (2008) There isContinue reading “Thinking Fast, and Slow……About Tax.”

Capital in the Twenty First Century. And Tax.

Because something is happening here, but you don’t know what it is, do you, Mister Jones? – Ballad of a Thin Man, Highway Revisited, 1965 Qui dit étude dit travail, Qui dit taf te dit les thunes, Qui dit argent dit dépenses, Qui dit crédit dit créance, Qui dit dette te dit huissier… Alors onContinue reading “Capital in the Twenty First Century. And Tax.”

The Lost and Found Discipline of Negotiation

Diplomacy is the art of letting someone else have your way. –    Sir David Frost An onslaught of judicial review claims has been predicted in light of the introduction of ‘follower notices’ by the Finance Act 2014. My own view, however, is that the review option will not be needed in genuine cases ofContinue reading “The Lost and Found Discipline of Negotiation”

Mixed Partnerships: Communique

Schedule 13 of the Finance Act 2014 will introduce a raft of rules pertaining to partnerships. The ‘salaried members’ and ‘mixed partnership’ rules are the most far-reaching of these (but by no means the only!). The salaried members rules are domestic in scope, whereas the mixed partnership rules can apply to offshore entities too. MyContinue reading “Mixed Partnerships: Communique”

Love ‘actually’: Employment-related loans and the Leeds Design case

The most important thing in communication is to hear what isn’t being said. – Peter Drucker There is much to comment on the decision of the First-tier tribunal in the Leeds Design case. However, in this short piece, I intend only to content myself to the examination of a sole point. The wide plethora ofContinue reading “Love ‘actually’: Employment-related loans and the Leeds Design case”

(SUPER)ATED – 10 Strategies

I want a house that has got over all it’s troubles… – Jerome K Jerome They and I (1909) superated: adjective (archaic) overcome, surmounted, surpassed – Collins English Dictionary This is article on a speech I delivered at the M5 Conference at Oxford in October 2013 titled A-Ten: Ten Strategies for ATED. This article will be completed hereContinue reading “(SUPER)ATED – 10 Strategies”