![](/sites/default/files/styles/medium/public/picture-33641.jpg?itok=GxoWGrgt)
![](/sites/default/files/styles/medium/public/picture-33641.jpg?itok=GxoWGrgt)
The statutory residence test: defining ‘exceptional circumstances’
The circumstances underlying this case concern a series of family tragedies which I do not wish to belittle in any way....
Penetrating the obscuring mists of judicial precedent
In the December 2016 issue of Tax Adviser, my article ‘Return of the naïve’ looked at the Upper Tribunal case of Hardy v...
The loss-carry back rules following an increase in earlier profits
The combined cases of Peter Lowe and Civic Environmental Systems Ltd v HMRC [2022] UKUT 84 (TCC) addressed three very di...
Embiricos: the scope of partial closure notices
The original Self-Assessment code was drafted almost 30 years ago and it might be said that its age is showing in places...
Quinn: the complexity of enhanced R&D rules
Until a couple of years ago, relief for research and development expenditure was a subject that did not attract much att...
Kunjur: Deductibility of accommodation expenses
It is well known that the deductibility of expenses for employees is much tougher than for the self-employed....
Salaried partner, hidden tax charge
It is probably a sign of my advancing years, but I still consider the advent of limited liability partnerships (LLPs) to...
Our Mutual Friend
In the November 2018 issue of Tax Adviser, my article ‘Men in Black’ considered the First-tier Tribunal’s decision in th...
The Benchdollar Question
In the June 2018 issue of Tax Adviser, my article ‘The 64-8 questi on’ considered what was then a recent decision of the...
Murphy’s Law
It is well known that the rules for obtaining a tax-allowable deduction from employment income are particularly restrict...