I recently had the following article published by HMRC Tax Investigations Enquiries and Powers magazine. Definitely worth a subscription for those interested in tax disputes. PDF Andy Wood CARF and the Crypto whale
“Cannot see the wood for the trees.” The phrase is often attributed to Sir Thomas More, writing in the early 16th century in his catchily titled The Confutation of Tyndale’s Answer. Nearly 500 years later, a similar sentiment appears in Lady Justice Falk’s judgment in Currell v HMRC. But let’s rewind. — Back in September […]
INTRODUCTION In the first part of this article on the catchy new “Prohibition against unregistered tax advisers interacting with HMRC”, we looked at: Why these provisions have been introduced; What these rules are and how they will be implemented When they will be introduced The ‘so what?’ Who the rules apply to In Part Two, […]
WARM UP ACT As is obvious from the title, this article considers the new “Prohibition against unregistered tax advisers interacting with HMRC”. What? It wasn’t obvious? Ok, well, from 18 May 2026, if you’re paid and you interact with HMRC about someone else’s tax affairs, your legal entity needs to register unless an exemption applies. […]
Introduction The coverage of this month’s vintage‑guitar “gold rush” is a reminder that ‘passion’ assets don’t just capture hearts… Yes, I am talking about the sale of Jim Irsay’s amazing collection of guitars. Irsay was an American billionaire businessman who died last year. He was the principal owner, chairman, and CEO of the Indianapolis Colts of the National Football […]