HMRC beat a hasty retreat on treaty anti-avoidance but it remains to be seen whether the OECD will back off from the ‘beneficial ownership’ debate. Momentum gathers in Europe for a common corporate tax base and a financial transactions tax. The IRS have delayed implementation of FATCA withholding to give financial institutions more time to get the necessary systems in place. Tax opacity is restored to US LLCs by the Upper Tribunal’s decision in Anson (Swift). The First-tier Tribunal applies FA 1996 Sch 9 para 13 after a cursory analysis in Explainaway. Retrospective tax legislation is found not to contravene the Human Rights Act in
