May 30th, 2024

Lights, camera, (fraud) action? HSBC succeed in Fraud Defence

High Court Rules in Favour of HSBC in Film  Tax Scheme Fraud Claim – Introduction In the case of Upham and others v HSBC UK Bank Plc [2024] EWHC 849, the High Court ruled that HSBC was not liable for deceiving hundreds of investors in a £1.3 billion fraud claim. The claim centered on allegations […]

March 10th, 2024

Non-Dom Might be Gone… but what about their non-resident trusts?

Non dom changes and trust – Introduction In the latest budget announcements, non-domiciled individuals and trusts have been thrust into the spotlight, heralding potentially significant changes to how these trusty trust vehicles might be taxed. These changes will have key implications for non-UK resident trusts and their beneficiaries. As we await a more detailed analysis, […]

March 6th, 2024

Non Dom Rules Abolished – Hunt’s changes are more NZ than Italy

Non Dom Rules Abolished – Introduction Well, my Michael Caine and Italian Job material was totally wasted as what actually materialised looks little like the Italian flat tax system. Instead, we have a regime that looks pretty similar to New Zealand’s 49 month exemption for overseas income and gains for those immigrating to the country. […]

March 6th, 2024

Jeremy Hunt’s Non-Dom Italian Job?

So, the random musings in my social media posts over the weekend seem to have the strong, Gorgonzola-like whiff of the truth.   It looks as though Hunt will be blowing the bleedin doors off the current non-Dom regime and doing an Italian job in this afternoon’s 2024 Budget.   This is on the basis […]

January 30th, 2024

Bills of exchange: magic money or magic beans?

An opening confession   I confess. I have a bad habit.   I will liberally use “clearly” and “obviously” when explaining tax.   The thing with UK tax is that these are liberties one shouldn’t take. I mentioned this in an old article – “how to make a peanut butter and banana sandwich”.   But […]