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Profile
Work Department
Position
All aspects of revenue law, including VAT and tax-related judicial review. Specialities include director and employee remuneration, owned-managed companies, the GAAR, Follower Notices and Accelerated Payment Notices, DOTAS, litigation, trusts, EU, offshore and international. Recent and landmark cases: Daniel v HMRC (2014), Loyalty Management Ltd v Commissioners of Customs and Excise [2007]; BUPA Hospitals Ltd v Commissioners of Customs and Excise ECJ [2006], Greenalls Management Ltd v Commissioners of Customs and Excise [2005] UKHL, excise duties, Jerome v Kelly [2004] UKHL 25, CGT, gift to offshore trustees; Howell v Trippier [2004] EWCA Civ 885, income tax liability of trustees of a settlement on stock dividends; Mount Murray Country Club Ltd v Macleod UKPC 53; Unilever (UK) Holdings Ltd v Smith [2002]. EWCA Civ 1787, corporation tax on capital gains, corporate reorganisations; R v Dimsey [2001] UKHL 46; Lady Ingram’s Executors v Inland Revenue Commissioners [1998] (House of Lords), inheritance tax.
Career
- Called 1973; KC 1990.
- Chairman of the Revenue Bar Association of England and Wales 2001-05
- Bencher of the Middle Temple (Elected 1999)
- Council Member of the Chartered Institute of Taxation and Chartered Tax Adviser (from 1999)
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