July 20th, 2026
After the Upper Tribunal decided in favour of the Elborne family, I wrote about the old IHT double-trust home loan scheme and HMRC’s unsuccessful attempts to prevent the £1.8 million promissory note from reducing the value of Mrs Elborne’s estate. The Court of Appeal has now unanimously dismissed all ten grounds of HMRC’s appeal in […]
July 16th, 2026
When I first sent Horse into the bar, he had been paid in USDT and discovered that every pint, and every favourite salt lick, could require a Capital Gains Tax computation. HMRC’s call for evidence gave Horse hope. Never to disappoint its equine citizens, the government has now published draft legislation that should remove this […]
July 16th, 2026
Three years after consulting on a regime based on the repo and stock-lending rules, the government has published draft legislation for cryptoasset loans and liquidity pools. The result is much closer to the no gain, no loss approach that was originally left on the sidelines. Read on for my initial take on this draft legislation […]
May 20th, 2026
In November 2023, I wrote a piece called “Educating Shakira” about the Colombian singer’s long-running battle with Spain’s tax authority (AEAT). At the time, she’d just settled with prosecutors, accepting six charges of tax fraud, a €7.3 million fine, and a suspended three-year prison sentence. She said settling was about protecting her children and her […]
May 16th, 2026
Introduction Christopher Nolan’s The Odyssey arrives in cinemas in July 2026. Universal describes it as bringing Homer’s foundational saga to IMAX film screens. Firstly, I am not Homer[1]. But this feels oddly well-timed for those of us who have embarked on their own odyssey over the years following Baxendale-Waker’s (“BW”) Remuneration Trusts (“RTs”). The UK’s […]
