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”

TAA and the Overkill Defence

TAA and the Overkill Defence Best to be prudent and kill them all, God will know his own kind! – The Bishop at the gates of Beziers First, A Past Instance of Overkill Sometimes in the course of his or her submissions, a barrister will employ the technique of reductio ad absurdum, such as thatContinue reading “TAA and the Overkill Defence”

The Statutory Residence Test

This piece is based on a speech I delivered at the Tax Chambers seminar in April 2013. 1. Background to the recent consultation and legislation HMRC withdrew their publication, IR20 in 2009. IR20 had been relied upon by many thousands of taxpayers in good faith since its introduction in 1973. It was thought to provideContinue reading “The Statutory Residence Test”