My practice is an interesting mix of transactional and advisory work. On the transactional side, I am busy on real estate financings, debt restructurings and M&A deals. On the advisory side, I have instructions from long-standing clients on some of the trickier tax points arising in their businesses.
I was recently promoted to partner (along with two fantastic colleagues in the tax team), so I am also spending a lot of time ensuring we train and retain the best talent. More generally, it is great to be back working in the office more regularly. There is nothing quite like popping into a colleague’s office, tax books in hand, to discuss a thorny issue.
If you could make one change to tax, what would it be?
As an avid reader of ‘One minute with’ over the years, I always imagined myself answering this question with some sort of ‘humble brag’ about the inconvenient impact of some new and technical tax legislation on my incredibly complex deals. Now it comes down to it, my simple tax wish would be for same day stamping on stock transfer forms. You’re welcome.
What do you know now that you wish you’d known at the start of your career?
First, it’s fine not to know the answer immediately. Very few tax questions can be answered on the spot, without at the very least going back to the relevant materials to check what you thought you already knew. Clients expect and accept that most of the tax issues they raise require varying degrees of consideration and judgement.
Second, seek out colleagues and counterparts with a style of advising or negotiating that most resonates with you and try to emulate it. There is room for a range of different approaches in this industry, but it is much easier to deal with the various stresses and strains of working life if you adopt the approach most authentic to you.
Has a recent tax case caught your eye?
The recent case of JTI Acquisition Company (2011) v HMRC (TC/2019/04496) has caused quite a stir. John Gardner QC seemed aghast that the core commercial transaction could give rise to a claim of ‘unallowable purpose’ and yet the FTT seemed to find it pretty easy to give this to HMRC. As Tax Journal has previously reported, it is a case of ‘watch this space’ on the appeal for this (for surely it will be appealed) and other recent ‘unallowable purpose’ cases to see where we end up.
What should we be looking out for later this year?
It seems to me we are in for some turbulent times ahead. We all need to be ready for anything.
Finally, you might not know this about me but...
I have been a volunteer at the Legal Advice Centre (University House) since I was a trainee. I say this not to get in a ‘humble brag’ after all, but really to shine a light on the work carried out by the Legal Advice Centre and similar organisations providing free legal advice because it is absolutely vital.
My practice is an interesting mix of transactional and advisory work. On the transactional side, I am busy on real estate financings, debt restructurings and M&A deals. On the advisory side, I have instructions from long-standing clients on some of the trickier tax points arising in their businesses.
I was recently promoted to partner (along with two fantastic colleagues in the tax team), so I am also spending a lot of time ensuring we train and retain the best talent. More generally, it is great to be back working in the office more regularly. There is nothing quite like popping into a colleague’s office, tax books in hand, to discuss a thorny issue.
If you could make one change to tax, what would it be?
As an avid reader of ‘One minute with’ over the years, I always imagined myself answering this question with some sort of ‘humble brag’ about the inconvenient impact of some new and technical tax legislation on my incredibly complex deals. Now it comes down to it, my simple tax wish would be for same day stamping on stock transfer forms. You’re welcome.
What do you know now that you wish you’d known at the start of your career?
First, it’s fine not to know the answer immediately. Very few tax questions can be answered on the spot, without at the very least going back to the relevant materials to check what you thought you already knew. Clients expect and accept that most of the tax issues they raise require varying degrees of consideration and judgement.
Second, seek out colleagues and counterparts with a style of advising or negotiating that most resonates with you and try to emulate it. There is room for a range of different approaches in this industry, but it is much easier to deal with the various stresses and strains of working life if you adopt the approach most authentic to you.
Has a recent tax case caught your eye?
The recent case of JTI Acquisition Company (2011) v HMRC (TC/2019/04496) has caused quite a stir. John Gardner QC seemed aghast that the core commercial transaction could give rise to a claim of ‘unallowable purpose’ and yet the FTT seemed to find it pretty easy to give this to HMRC. As Tax Journal has previously reported, it is a case of ‘watch this space’ on the appeal for this (for surely it will be appealed) and other recent ‘unallowable purpose’ cases to see where we end up.
What should we be looking out for later this year?
It seems to me we are in for some turbulent times ahead. We all need to be ready for anything.
Finally, you might not know this about me but...
I have been a volunteer at the Legal Advice Centre (University House) since I was a trainee. I say this not to get in a ‘humble brag’ after all, but really to shine a light on the work carried out by the Legal Advice Centre and similar organisations providing free legal advice because it is absolutely vital.
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