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Tax Barrister and Former Head of Chambers at Temple Tax
All types of tax advice, disputes and advocacy, Michael has been practising tax and providing solutions and representation for over 35 years, formerly Head of Chambers at Temple Tax, Michael has written extensively (Editor of Whiteman and Sherry on Income Tax and on Capital Gains Tax for many years) and lectures regularly and extensively. Michael has experience of all UK courts from the First-tier Tribunal to the Supreme Court.
While Michael's practice covers all the areas of taxation a particular emphasis over the years has been owner managed businesses, covering all the business taxes, remuneration planning, capital structures and inevitably succession planning and business sales. This has natural led on to Family Investment Companies, trusts and estate planning generally.
Recent advisory work includes helping individual residential landlords to incorporate their businesses (capital gains relief under TCGA 1992, section 162 and SDLT treatment for partnerships under FA 2003 Sched 15.)
Cases of Note include:
Langham v Veltema (CofA Discovery Assessments); College of Estate Management (HoL VAT separate/composite supplies); Hancock (SC CGT, securities, reorganisation); Forde & McHugh Ltd (SC NIC pension contributions); Padfield (tax schemes); Irving (CofA pension contributions); Reid & Emblin (scope of enquiry and closure notice); Mansworth v Jelley (CoA share options - employee with foreign service); Cumming Bruce (nature of claim to have capital losses treated as allowable); Guy Boardman (pension investment in tax scheme and pension unauthorised payment charge and surcharge)