This article was kindly published by Taxation Magazine in full on Tuesday 17 March 2026 Prologue Once upon a time there was a salesman. Let’s call him Rumpelstiltskin. He had a sales pitch. It went a little something like this: “You have some tax debts? You don’t need to use real money to settle it. […]
Introduction The Sweeney[1] is taken from the Sweeney Todd, which is cockney rhyming slang for the Flying Squad. The London criminal fraternity simply shortening it to The Sweeney. It is perhaps a less well known fact[2] that tax dodgers also use The Sweeney as rhyming slang for “The FTT”. For example, “my accountant has appealed […]
Introduction “Call me Ishmael” famously begins Moby Dick. And now, as it happens, so does this article. But whereas Melville’s book is about Captain Ahab’s unhealthy obsession with a white whale, this article is about a different kind of whale. Crypto whales: individuals and groups whose crypto holdings are large enough to matter. Ahab’s harpoon […]
Introduction Admiral Horatio Nelson, one day, decides to buy a fine Georgian townhouse in Plymouth. His lawyer warns him via WhatsApp that “I’m no expert in this matter. However, I think you might need to pay the higher SDLT surcharge for second homes, my Lord. I suggest we get some expert advice.” Nelson, never one […]
THIS ARTICLE WAS ALSO PUBLISHED IN TAXATION MAGAZINE HERE. Introduction In the first part of this two part-er, I looked at BW’s remuneration trusts and the type of loans provided by the trustees of such arrangements. This line of cases has shown that, despite HMRC’s protestations, that the decision in Rangers has its limitations when […]