March 6th, 2026
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 […]
February 10th, 2026
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 […]
September 10th, 2025
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 […]
July 24th, 2025
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 […]
July 17th, 2025
THIS ARTICLE WAS ALSO PUBLISHED IN TAXATION MAGAZINE HERE. INTRODUCTION When I first started writing this article, I was going to look at two quite different tax schemes which had some interesting similarities. The cases were MR Curell v HMRC[1] (“Currell”), a Baxendale-Walker (“BW”) remuneration trust and The Executors of Mrs Leslie Vivienne Elborne Deceased […]
