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Partners in tax
As I noted in my January 2020 article ‘What a carry-back!’, there remain a number of unresolved questions concerning the...
An officer and an automaton
Over the past few years, doubts have been raised about whether the Taxes Management Act (TMA) 1970 has kept up with HMRC...
A golden contract
The concept of enterprise zones (EZs) was born in the first year or so of Mrs Thatcher’s premiership....
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What a carry-back!
When working on the Tax Law Rewrite Project at the turn of the millennium, I was told that there had been a recent deleg...
Stuck in second gear
In the January 2018 issue of Tax Adviser, I wrote an article ‘Manual transmission’ in which I considered the High...
An inspector calls
It is inevitable that there will be occasions when HMRC will want to look at a taxpayer’s records or those held by a thi...
The loan arrangers
The current controversy surrounding the 2019 loan charge concerns arrangements where earnings were received in the form ...
Hancock's half-decent argument
Writing about tax is a wonderful hobby. I have friends all over the country – none in HMRC perhaps, but friends elsewher...
Jaws 2
Background When I ran my first few discovery cases (including Charlton, Sanderson and Pattullo), it was necess...
