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Volume IX Number 2
June 2010
Flip Flop Schemes and Burton
by Imran Afzal
Section 42 Finance Act 1998 - An Opportunity Missed?
by Barrie Akin
Dividends: A Flow-chart of the New Regime
by Felicity Cullen QC
Mr. Lee
by Milton Grundy
Growing (Capital) Pains in Indian Taxation and Other Fiscal Ailments for Foreign Investors
by Nikhil Mehta
Treaties Which Override the IHT Deemed Domicile Rules
by Patrick Soares
Residence and Zero Rate of Tax Jurisdictions
by Laurent Sykes
Image Rights after Finance Act 2010
by Patrick Way
Volume IX Number 1
December 2009
Purpose or Intendment: Spot the Difference
by Michael Flesch QC
On the Nature, of Reality
by David Goldberg QC
Le Lac
by Milton Grundy
Thoughts on Drummond and the Judicial Approach to Tax Avoidance
by Imran Afzal
Stamp Duty: an Epilogue - the decision in Parinv in aid of the taxpayer
by Marika Lemos
Some Observations on the Residence of Corporate Trustees
by Aparna Nathan
What Reverse Premiums are Tax Free?
by Patrick Soares
Property Tax Planning: the Future is Capital and Loans
by Patrick Soares
Volume VIII Number 3
June 2009
Smallwood: the high Court Decision
by Philip Baker QC
Sub-Funds - deem, deem, deem?
by Felicity Cullen QC
Thoughts on Corporate Residence
by David Goldberg QC
Tax Planning in Pre-packaged Administrations
by Michael Jones
Avoiding Land Trading Transactions
by Patrick Soares
Decisions, decisions: challenging a decision of the Tax Tribunal
by Laurent Sykes
The Enterprise Investment Scheme after Blackburn
by Patrick Way
Volume VIII - Number 2
April 2009
The Principessa
by Milton Grundy
Nelson Dance and Business Property Relief
by Marika Lemos
Contemplating Grace: The impact of RCC v. Grace on the Test for Determining Individual Residence
by Aparna Nathan
Avoiding the Order of Remittance Rules by Having a "Golden" Bank Account
by Patrick Soares
Making Sense of s.809L
by Laurent Sykes
Real Estate Tax in a Tough Climate
by Michael Thomas
The 2009 Reforms of the Tax Appeals Tribunals
by John Walters QC
Volume VIII - Number 1
November 2008
Private Foundations - An aspect of the Remittance Basis
by Felicity Cullen QC
Tax Avoidance in Practice
by David Goldberg QC
Miscellaneous Points on VAT and Property
by David Goy QC
CFC Code Removed from Statute Book by Judge
by Laurent Sykes
EBTs and FBTs after Sempra
by Patrick Way
Letter to the Editor From Tony Foreman
Volume VII Number 2
June 2008
Offshore Business Centres: A World Survey
by Felicity Cullen QC
Mars and Secan: There Illusion and Here Truth; the Computation of Profit
by David Goldberg QC
Case Note: Smallwood v. Revenue & Customs Commissioners
by Milton Grundy
Every Second Counts: Limits on HMRC's Power to Recover NICs
by Michael Jones
Using Family Trading Trusts for Land Deals - Stopping Tax at the Basic Rate
by Patrick Soares
The Changes to the Remittance Basis and New Structures
by Patrick Soares
The Tax Treatment of Termination Payments: a Short Review
by Michael Thomas
Volume VII - Number 1
December 2007
Depreciation and Trading Stock - Confusion Unconfounded
by Barrie Akin
"Benefit": A Note
by Milton Grundy
Abuse of Rights II - WHA: The Electon on Closer Inspection
by Hui Ling McCarthy
The United Kingdom as an Offshore Centre
by Aparna Nathan
Recent Trends in Tax Litigation
by Michael Thomas
Volume VI - Number 2
June 2007
Beneficiaries of Trusts and Foundations
By Philip Baker QC
The Ordinary and Extraordinary Power of the European Court of Justice
By David Goldberg QC
The Smith Story
By Milton Grundy
Abuse of Rights - Europe's Legal Elephant
By Hui Ling McCarthy
Section 75A FA 2003: the Death of SDLT Planning?
By Michael Thomas
Volume VI - Number 1
February 2007
Compulsory Purchase and Rollover Relief
By Barrie Akin
Beneficial Ownership - after Indofood
By Philip Baker QC
The Music Between the Notes: A review of "More Essays in International Tax Planning" by Milton Grundy
By Conrad McDonnell
Cyganik v. Agulian: Determining Domicile of Choice
By Aparna Nathan
Litigate or Die
By Patrick Way
Volume V - Number 2
May 2006
Tax Aspects of Rectification
By Barrie Akin
Payments for Share Capital and s.419 ICTA 1988
By Felicity Cullen
Double Tax Treaties and ss.739 and 740 ICTA 1988
By David Goy QC
College of Estate Management v. Customs & Excise Commissioners [2005] STC 1597: Case Note and Commentary
By Nicola Shaw
If Ramsay Were in Statutory Form
By Patrick Soares
Stamp Duty Land Tax ("SDLT") and Partnerships: An Introduction
By Michael Thomas
Volume V - Number 1
November 2005
Company Residence after Wood v. Holden
By Aparna Nathan
Section 80 TCGA 1992: in Breach of Community Law?
By Claire Simpson
Points of View
By Patrick Soares
Overage Agreements and Related SDLT Issues in Property Transactions
By Michael Thomas
Individual Residence and s.334
By John Walters QC
Dextra - Its Not Over Till the Fat Lady Sings and Other Cliches
By Patrick Way
Volume IV - Number 2
May 2005
The Problem is Perception
By David Goldberg QC
Treaty-Shopping through Life Assurance
By Milton Grundy
Volume IV - Number 1
November 2004
Book Review: “The Saving of Income Tax, Surtax and Death Duties” by Jasper More
By Philip Baker QC
Words From The Heart: Tax Avoidance of the Third Kind; the Lessons of Schrodinger’s Cat
By David Goldberg QC
Disclosure
By Patrick Way
Volume III - Number 2
April 2004
The World-Wide Response to the Harmful Tax Competition Campaigns
By Philip Baker QC
No Loss All Gain for Non-resident Companies
By Felicity Cullen
Property Dealers: Why not set up your own FURBS?
By Patrick Soares
VAT and alterations to listed buildings – the Zielinski Baker appeal
By John Walters QC
The Ramsay principle: where are we now?
By Patrick Way
Volume III - Number 1
November 2003
Stamp Duty Land Tax by Michael Thomas – A Review
by David Goldberg QC
Home Thoughts from Abroad
By Milton Grundy
Just Supposing ….
By Hugh McKay
MARD – Issues arising from the Mutual Assistance in the Recovery of Debts Directive
By Aparna Nathan
Volume II - Number 2
April 2003
Tax and Damages (1)
By Conrad McDonnell
Tax and Damages (2)
By Harvey McGregor QC
Tax and the Proceeds of Crime
By Nicola Shaw
The Influence of the European Court – Recent and Forthcoming Tax Cases
By Claire Simpson
Practical Inheritance Tax Planning – an overview
By Michael Thomas
Tax and Damages (3)
By John Walters QC
Employee Benefit Trusts
By Patrick Way
Volume II - Number 1
November 2002
The Application of the Convention to Partnerships, Trusts and other, Non-Corporate Entities
By Philip Baker QC
The Legal Adviser’s Responsibility
By David Goldberg QC
Disposals by Companies With Substantial Shareholdings
By David Goy QC
The Limited Partnership: A UK vehicle for non-residents with non-UK income
By Milton Grundy and Michael Thomas
IHT Planning – the Gift With Reversion Approach
By Patrick Soares
Modernising Stamp Duty on Land and Buildings in the United Kingdom
By Patrick Way
Volume I - Number 2
May 2002
Volume I - Number 1
November 2001 |
