January 8th, 2024

A line in the sand for Jordan Henderson?

A line in the sand for Jordan Henderson – Introduction It was only at the end of last summer I found myself doing an impromptu master class on a whiteboard in the offices of a football agency. The topic was UK tax residence and the example I was using was Jordan Henderson (not my client […]

January 1st, 2024

2023: A tax odyssey

Introduction   So, 2023 has ground to a conclusion.   Like an expiring, wet and windy sunset clause.   But how was it for you tax fans?   Here’s my review of the tax year. Not THE tax year. The calendar year in tax.   Apes a-taxing?   Well, Kubrick’s titular masterpiece was a bold […]

December 16th, 2023

Property hybrid structure… or property chimera?

Property hybrid structure – Introduction In Greek mythology, the Chimera was a monstrous fire-breathing hybrid creature with the head and body of a lion, the head of a goat emerging from its back, and the tail of a snake. It was the offspring of Typhon, a monstrous giant, and Echidna, a half-woman, half-snake creature. So, […]

December 9th, 2023

“These are not the tax advocates you are looking for…”

In a tax tribunal, far, far away Felicity Harber, an unrepresented taxpayer or Litigant in Person, lost her appeal at the First Tier Tribunal (FTT) after submitting nine fabricated tax rulings generated by Artificial Intelligence (AI) to support her case. Although the details of her case seem almost irrelevant: Harber disputed a £3,265.11 demand from […]

December 8th, 2023

NUFC v HMRC: the right to retain seized material clarified

NUFC v HMRC: Introduction After being battered by the mighty Toffees (#UTFT) last night, we’re left wondering who has had the worst week or so: Kieran Trippier after his brace of howlers or the legal team of Newcastle United (“NUFC”). Yes, as November turned into December, the Administrative Court delivered a significant ruling in the […]