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 […]
March 13th, 2025
“Dance your cares away… …worries for another day.” A great mantra from the Fraggles and one which someone like me, who catastrophises daily about all manner of things, should probably take on board[1]. Let’s all be more Fraggle. But, only to a point. You see, when it comes to tax and investment planning that approach […]
January 14th, 2025
THE END OF THE REMITTANCE BASIS – PART TWO In this second part, I talk about the post-April 2025 rules. If you want to know what these rules are replacing, I suggest you hope to the first part. Go on, scram! THE NEW RULES Individuals IT & CGT – The new 4 year Foreign Income […]
December 14th, 2024
THE END OF THE REMITTANCE BASIS – PART ONE In this first part of a two part extravaganza, I will talk about the pre-April 2025 rules. In the second part, I will discuss what comes after. How exciting, eh? INTRODUCTION Background – The British Bulldog v French Bulldog At the dying end of the 18th […]
