You have a very varied background – from inspector of taxes to working as a partner at a ‘big four’ accountancy firm, reading for the Bar and setting up your own practice. What would you say has been the standout moment in your career?
There have been a couple of such moments. When I qualified as a chartered accountant, I won a couple of prizes (neither of them for tax) and was able to take my parents, who were getting quite elderly then, to a reception at the institute’s offices, which made them tremendously happy. The second one was the moment when, having left KPMG, I realised I could run an independent business.
What advice would you give to someone new to the profession?
I would advise a new entrant to get a very broad introduction; it is a great mistake to specialise too early. I once worked with someone who was one of the UK’s greatest experts on development land tax (for those of you who are over 50). When they abolished the tax, his practice effectively disappeared.
Comment on a topical tax issue.
I am particularly interested in the proposals to apply UK inheritance tax to foreign persons and entities that own UK residential property. I am fascinated as to how that is going to be made to work in practice and fear that the compliance problems may be enormous.
What advice would you give HMRC?
HMRC is still pursuing the holy grail of income tax and NICs on contributions to all sorts of EBTs. HMRC has consistently failed to win cases, but the settlement of thousands of outstanding issues is bogged down because it still takes the position that its arguments are right. Given that this is no longer a current problem because extractions from such structures are taxed to income tax, would HMRC not be far better to abandon this argument and resolve all these old cases before the underlying companies become insolvent?
If you could make one change to UK tax law, what would it be?
The one change I would make would be in the area of employment-related securities. There is only one real issue: if the shares or securities in some way give guaranteed returns for an executive, they should be taxed as income; in every other circumstance, they should be taxed as capital and with entrepreneurs’ relief. That would give a real boost to getting employees involved in companies.
Aside from your immediate colleagues, whom in tax do you most admire?
I have had enormous admiration for the work Graham Aaronson did on the GAAR. It has obviously drifted a bit in favour of HMRC from his original intention, but he provided some real intellectual rigour in dealing with an issue which could have been a much greater threat to civil liberties than it has turned out to be.
You might not know this about me but...
I am one of the luckiest people in the world because I work for enjoyment. I was lucky enough to make quite a lot of money a few years ago by buying and selling a non-tax related business, but I won’t give up solving tax problems because it strikes me as more fun than anything else I could spend my time doing – even though it can be stressful at times.
You have a very varied background – from inspector of taxes to working as a partner at a ‘big four’ accountancy firm, reading for the Bar and setting up your own practice. What would you say has been the standout moment in your career?
There have been a couple of such moments. When I qualified as a chartered accountant, I won a couple of prizes (neither of them for tax) and was able to take my parents, who were getting quite elderly then, to a reception at the institute’s offices, which made them tremendously happy. The second one was the moment when, having left KPMG, I realised I could run an independent business.
What advice would you give to someone new to the profession?
I would advise a new entrant to get a very broad introduction; it is a great mistake to specialise too early. I once worked with someone who was one of the UK’s greatest experts on development land tax (for those of you who are over 50). When they abolished the tax, his practice effectively disappeared.
Comment on a topical tax issue.
I am particularly interested in the proposals to apply UK inheritance tax to foreign persons and entities that own UK residential property. I am fascinated as to how that is going to be made to work in practice and fear that the compliance problems may be enormous.
What advice would you give HMRC?
HMRC is still pursuing the holy grail of income tax and NICs on contributions to all sorts of EBTs. HMRC has consistently failed to win cases, but the settlement of thousands of outstanding issues is bogged down because it still takes the position that its arguments are right. Given that this is no longer a current problem because extractions from such structures are taxed to income tax, would HMRC not be far better to abandon this argument and resolve all these old cases before the underlying companies become insolvent?
If you could make one change to UK tax law, what would it be?
The one change I would make would be in the area of employment-related securities. There is only one real issue: if the shares or securities in some way give guaranteed returns for an executive, they should be taxed as income; in every other circumstance, they should be taxed as capital and with entrepreneurs’ relief. That would give a real boost to getting employees involved in companies.
Aside from your immediate colleagues, whom in tax do you most admire?
I have had enormous admiration for the work Graham Aaronson did on the GAAR. It has obviously drifted a bit in favour of HMRC from his original intention, but he provided some real intellectual rigour in dealing with an issue which could have been a much greater threat to civil liberties than it has turned out to be.
You might not know this about me but...
I am one of the luckiest people in the world because I work for enjoyment. I was lucky enough to make quite a lot of money a few years ago by buying and selling a non-tax related business, but I won’t give up solving tax problems because it strikes me as more fun than anything else I could spend my time doing – even though it can be stressful at times.
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