August 22nd, 2026
Introduction The Duke and Duchess of Sussex are returning to the UK after more than five years in California… and tax experts have noted that their timing may have saved them from the reach of Britain’s temporary non-residence rules. Whether this was planning or providence is unclear, but the tax implications are worth examining. Prince […]
August 1st, 2026
Introduction A few years ago, I wrote an article asking whether Property 118’s landlord incorporation structure was really “the worst tax avoidance scheme of all time”. My conclusion was that IMO it was not a tax avoidance scheme at all. However, there were / are three separate questions rolled into one: Is the arrangement tax […]
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 […]
