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was called to the Bar in 2006, having obtained a distinction on the BCL at Oxford University and a first-class law degree at the University of Nottingham. He won a number of academic prizes, including for tax law, and was awarded Hardwicke, Denning and Megarry Scholarships by Lincoln’s Inn. At Bar School he came top of his year, winning the Taylor and Buchanan Prizes.
Michael’s practice involves an even mix of advisory and litigation work and he is instructed to advise and represent in court both taxpayers and HM Revenue and Customs. In 2010 he was appointed by the Attorney General as Junior Counsel to the Crown (C Panel). He is recommended as a tax junior in Chambers and Partners.
On the litigation side Michael is regularly instructed to act for both taxpayers and HMRC in relation to tax disputes and investigations in all areas of tax law.
He has extensive experience of tax appeals, judicial review claims and other tax-related actions (including restitutionary claims against HMRC, enforcement proceedings and tax deed disputes) and has appeared in County Courts, the Tax Tribunals, the High Court and the Court of Appeal.
In addition to appearing in court Michael is regularly involved in settling pleadings, advising on evidence and providing advice on litigation strategy.
The advisory side his practice covers the full spectrum of tax law but with a focus on all aspects of corporate and commercial tax and VAT work, including:
- the taxation of corporate finance (particularly loan relationships and derivatives)
- M&A (especially transaction structuring, tax deeds and warranties)
- shareholder taxation
- employment tax (including share schemes and EBTs)
- company reorganisations and reconstructions
- debt restructuring (including the tax treatment of debt-for-equity swaps, debt buy-backs and subordination)
- property taxation and SDLT
- tax aspects of “distressed M&A”
- the tax treatment of trusts in a commercial context
Michael has considerable experience of corporate restructuring and insolvency-related tax work and has been instructed on several high profile insolvencies during the economic downturn. In this regard he has advised creditors, office holders and insolvent companies and his experience includes:
- COMI migration
- Group relief in insolvency
- Tax planning in administration and liquidation
- CVA taxation
- Tax aspects of set-off
- Pre-packs
- Pension fund restructuring
Michael also has extensive experience of the taxation of alternative investment funds, especially in relation to private equity funds (particularly carried interest structuring), hedge funds (covering fund structuring, reorganisation and re-domiciliation and investor taxation) and property investment funds (particularly fund structuring and investor taxation).
He is regularly asked to lecture and write on these subjects and was recently invited to contribute to Kerr and Hunter on Receivers and Administrators (19th ed) Sweet and Maxwell (2009), the leading work on the subject.
Outside work he is keen on most sports, (nowadays mainly as a spectator), but is especially passionate about rugby. He also enjoys hill-walking, puzzles and crosswords. |
