Research library

The UK Is Now Criminalising Tax Planning Advice

Part 6 of the Finance Act 2026 creates criminal liability for broadly defined promotion of tax arrangements, without requiring knowledge that the arrangements are prohibi

TRUMP’S EUROPE: NEW DEAL OR OLD STEAL

INTERNATIONAL EMPLOYEE BENEFIT TRUSTS

UK Tax Court Rulings Chaos Internation al employers use EBTs to reward employees. The tax treatment on both dies of the pond used to be clear and broadly in harmony. US C

Why WPIF

The 21st century was supposed to be the information era.Instead, we swim through endless currents of Misinformation, cramped by tidal waves of Censorship.Thanks for readi

WHO TO EXCLUDE

Trusts are about including people or purposes (“Objects”) to receive benefits.Trustees are usually excluded, so as to exclude conflict between their interests and duties.

WHISTLEBLOWERS DEMAND ACTION

Demands for action by the NWC:https://www.whistleblowers.org/seven-major-campaigns-of-2025/Thanks for reading! Subscribe for free to receive new posts and support my work

WHISTLEBLOWER BLOWN

Unflattering further light is cast by the decision of The August 8, 2025 decision of the United States Court of Appeals for The District Of Columbia Circuit, on Appeal fr

WHEN WE DID NOT HAVE A FEDERAL INCOME TAX

A useful post which puts into perspective the current state of US taxes and deficits:Income tax plays a central role in the American economic system today, but its origin

WHAT IS A TRUST DEED?

The idea of Trust Deeds is bandied around in commercial literature. It features in commentaries on wealth planning and taxation law across all jurisdictions which recogni

WEALTH TAX AT THE EDGE Consequences Not Being Considered

The UK polity is teetering on the edge of a wealth tax. Taking that course would make the UK an outlier in international taxation regimes:https://www.pgpf.org/article/wha

USE OF BEHAVIOURAL PSYCHOLOGY BY TAX AUTHORITIES

Tax authorities in several jurisdictions use behavioural psychology to advance tax compliance.The National Taxpayer Advocate has published a paperThanks for reading! Subs

US GOLD REVALUATION?

Forbes reports:The Treasury Is Sitting On A $750 Billion Gold Hoard Officially Valued At $11 BillionThanks for reading! Subscribe for free to receive new posts and suppor

UNCONSTITUTIONAL SEARCH & SEIZURE IN ITALY

The International Tax Review reportsItaly’s evolving tax audit rules face ECHR compliance test after key judgmentPaolo Ludovici, Andrea Iannaccone, Marlinda GianfrateThan

UK TO TAX LIFETIME GIFTS?

In the US, nobody in the middle class pays death tax, or estate duty or gift tax. In the UK, the position is more nuanced:https://www.gov.uk/government/publications/inher

UK TAX AUTHORITY USE OF AI

Matt Kenyon writes (August 8, 2025):HMRC must disclose AI involvement in tax decisionsThanks for reading! Subscribe for free to receive new posts and support my work.A co

UK TAX AUTHORITY TO TAKE TAX DEBTS WITHOUT COURT ORDER

HMRC has announced:The vast majority of taxpayers pay their taxes in full and on time, but a minority choose not to pay, even though they have the means to do so.Thanks f

UK TAX AUTHORITY SAY LAWYERS SHOULD NOT GIVE TAX ADVICE

City AM reports:Thursday 04 September 2025 3:02 pm | Updated: Thursday 04 September 2025 3:03 pmThanks for reading! Subscribe for free to receive new posts and support my

UK MANSIONS TAX PLAN

The UK’s Independent newspaper reports:Reeves’s ‘mansion tax’ makes ‘no sense’ and could lose Treasury money, former IFS chief warnsThanks for reading! Subscribe for free

UBO LAWS AND TRUSTS

Trusts are essential to the operation of national and international commerce. UBO laws around the world are destabilising the use of trusts.THE UBO LAWSThanks for reading

TWO MODELS OF TAX PSYCHOLOGY

Psychology has devoted substantial research into the reasons why people do pay tax, and even more to why people don’t: and what psychological techniques tax authorities c

TRUSTS AND SUITS

Trust jurisdictions around the world have long recognised protective clauses. Key examples are:· Spendthrift ClausesThanks for reading! Subscribe for free to receive new

TRUST BENEFITS TAXED AS WAGES IN AUSTRALIA

In Commissioner of Taxation v SEPL Pty Ltd as trustee of the SFT Trust [2025] FCA 581, Trustee directors were held to be employees for FBT purposes.The Federal Court has

TRUMP’S EUROPE: NEW DEAL OR OLD STEAL Lots of angst over the Trup Tariff Deal with the EU. But is it justified?

Trump’s White House says this:https://www.whitehouse.gov/fact-sheets/2025/07/fact-sheet-the-united-states-and-european-union-reach-massive-trade-deal/Thanks for reading!

TREATY TACTICS DEFENDING FREE SPEECH

There exist several important treaties between the US and UK. These include matters of:· Extradition· Taxation· Tax information exchangeNow that the UK is seeking to act

TRANSFORMATIVE ADVANCES IN HEALTHCARE AND ASSOCIATED ETHICAL CONSIDERATIONS

Highly anticipated advances in healthcare, such as personalised medicine are revolutionary but such precision comes with a minefield of privacy and related concerns. Ethi

THE VELOCITY OF MONEY Or is it?

DEFINITIONInvestopedia has a useful and commonly accepted definition:Thanks for reading! Subscribe for free to receive new posts and support my work.The velocity of money

THE UK’S PENSION DEATH TAX Behavioural changes to death tax policy

OLD RULESThe UK runs a death tax (Inheritance Tax: IHT). Under the old rules:Thanks for reading! Subscribe for free to receive new posts and support my work.https://www.g

THE NANNY STATE INDEX

The IEA, a UK based free-market thinktank, has published its:Nanny State Index 2025As written in Wikipedia:Thanks for reading! Subscribe for free to receive new posts and

THE MYTH OF GROWTH

An important analysis exposes the myth of growth:Did the United States grow its way out of WWII debt?by Tyler Cowen August 24, 2025 at 11:54 am inThanks for reading! Subs

THE GOOD AND BAD ABOUT TAX HAVENS

The Good and Bad about Tax HavensAugust 1, 2019Thanks for reading! Subscribe for free to receive new posts and support my work.By: Elke AsenHigh-tax countries have increa

THE FUTURE OF LUXURY LEISURE

In a world where wealth has unlocked alternate realities and money is no object, the rich no longer compete over money - they compete over meaning.Leisure pursuits are li

THE ECONOMICS OF SLEEP

A fascinating study in a matter which is foundational to the productive economy:Rand Health Q . 2017 Jan 1;6(4):11.Thanks for reading! Subscribe for free to receive new p

THE DEDUCTIBLE LOLITA EXPRESS?

Cady Stanton writes for Tax Notes:Wyden Questions IRS on Jeffrey Epstein’s Tax Planning ServicesThanks for reading! Subscribe for free to receive new posts and support my

THE CONSEQUENCES OF LOCAL TAX OFFICE CLOSURES

In the UK, Tony Monger explains the consequences of HMRC’s shut-down of local offices.The Third AnswerTony Monger travels through time to get to the roots of the tax auth

THE BRITISH FILM INDUSTRY-CUT!

Save a tear in Holly and Bolly Wood for the sad state of the British Film industry.Charlie Meyrick writes (January 16, 2025):Thanks for reading! Subscribe for free to rec

TAX POLICY AND FUNDAMENTAL FREEDOMS

There appears in EU individual State publications from time to time, the idea that States can impose taxes without constitutional limit.Some State taxation authorities cl

TAX HAVEN ECONOMICS

For the modern mercantilist view of tax haven economics, a standard screed is provided by:https://www.imf.org/en/Publications/fandd/issues/2019/09/tackling-global-tax-hav

SOCIAL MEDIA WATCHING BY TAX AUTHORITIES

If you are choosing to post windows onto your life online, tax authorities are watching.USAThanks for reading! Subscribe for free to receive new posts and support my work

SHOCK NEW TRUMP TARIFFS

CITY AM reports (August 24, 2025):Trump’s tariff salvo blindsides UK manufacturersThanks for reading! Subscribe for free to receive new posts and support my work.By: Sask

SHARE CAP TRAP

In the UK, the Companies Act 2006 sets out the rules at Part 17.Nicholas Campion explains (June 5, 2025)Thanks for reading! Subscribe for free to receive new posts and su

RONALD REAGAN WOULD HAVE HATED TARIFFS

Joseph J. Thorndike (August 4, 2025) writes an interesting opinion piece in Tax Notes.Ronald Reagan was no fan of tariffs. In fact, he was an ardent (if inconstant) champ

RESULTING TRUSTS CONTRADICTORY GUIDANCE FROM HMRC

HMRC (the UK tax authority) official guidance sets out the matter clearly:TSEM6241 - Legal background to trusts & estates: failure of trust provisionsThanks for reading!

PRIVACY - PERSONAL AND FINANCIAL

As well as considering the tax implications of various jurisdictions, individuals seeking discretion when considering where to place assets will need to weigh up privacy

New Tax Talk Censorship Laws in the UK Illegitimate, but can they be legal?

In the US, we take freedom of speech seriously: as guaranteed by the 1st Amendment.Congress shall make no law respecting an establishment of religion, or prohibiting the

NUMBERS FOR UK’S NON-DOM EXODUS

City AM reports:Tuesday 19 August 2025 6:00 am | Updated: Tuesday 19 August 2025 10:56 amThanks for reading! Subscribe for free to receive new posts and support my work.J

NEW UK PENSIONS TAX

City AM reports (August 21, 2025):Tax-free pension lump sum could be slashed to fill Labour’s black holeBy: Simon Hunt City EditorThanks for reading! Subscribe for free t

MY BROTHER’S KEEPER

Then the Lord said to Cain, “Where is your brother Abel?” “I don’t know,” he replied. “Am I my brother’s keeper?”: Genesis 4-9.It has widely been reported that accountanc

MORE OSA CONCERNS

Britain’s new Online Safety Law is causing worldwide chaos:Americans, Be Warned: Lessons From Reddit’s Chaotic UK Age Verification RolloutBy Molly Buckley and Molly Buckl

MORE ONLINE SAFETY ACT CRITICISM

EFF reports:Blocking Access to Harmful Content Will Not Protect Children Online, No Matter How Many Times UK Politicians Say SoBy Paige CollingsThanks for reading! Subscr

MMT V KEYNESIANISM

Richard Murphy is a well known UK based commentator:https://www.taxresearch.org.uk/Blog/Richard speaks in a useful YouTube presentation:Keynes vs MMT: which economic theo

MCANN OR MACAN’T? Troubles in the UK over their HMRC Loan Charge Scandal

Over on the UK, there is a tax policy scandal over the “Loan Charge”.Thanks for reading! Subscribe for free to receive new posts and support my work.https://www.computerw

MAKING SENSE OF FIDUCIARY RECEIPTS

The UK tax authority (HMRC) has issued some strange publication about Fiduciary Receipts. In order to see why they are strange, it is helpful to locate the legal concept

LOCATIONS WITH THE HIGHEST TAXES AND COST OF LIVING

The most expensive countries to live in usually have high costs for housing, food, transportation, healthcare, and general goods and services. These rankings often come f

LIBERTY GLOBAL AND ECONOMIC SUBSTANCE

The Liberty Global case is attracting widespread attention. Here’s why, and where it might lead.THE DECISIONThanks for reading! Subscribe for free to receive new posts an

LEAVING A LEGACY

“The great use of life is to spend it for something that will outlast it.” — William JamesThe concept of legacy reminds us to look beyond immediate achievements and focus

LAFFER CURVING

In Modern Monetary Theory, the Laffer Curve is a theory without an object. Taxation merely removes money from circulation, which money the State has placed into circulati

KNOW YOUR GLOBAL ELITES

The term “global elite” generally refers to a small, powerful group of individuals or organizations with disproportionate influence over global economic, political, and s

ITALY DECISION ON LOOK-THROUGH

Francesco Di Bari writes (22 April 2025)Italy: Landmark decision on the taxation of indirect lendingThanks for reading! Subscribe for free to receive new posts and suppor

INTERNATIONAL TAX COMPETITIVENESS INDEX

Important research. The 2025 rankings will be an interesting comparison.International Tax Competitiveness Index 2024October 21, 2024 By: Alex MengdenThanks for reading! S

INTERNATIONAL EMPLOYEE BENEFIT TRUSTS UK Tax Court Ruling Chaos

International employers use EBTs to reward employees. The tax treatment on both sides of the pond used to be clear and broadly in harmony.US CLARITYThanks for reading! Su

HOW MANY BILLIONAIRES?

Ali Lyon writes for City AM (July 16, 2025)HMRC doesn’t know how many billionaires are in BritainThanks for reading! Subscribe for free to receive new posts and support m

HISTORY OF ECONOMIC THOUGHT

For readers, an invaluable online resource:Just a couple of examples from this treasure trove.Thanks for reading! Subscribe for free to receive new posts and support my w

GO ANYWHERE BUT HERE, YOUNG MAN

Young Brits are thinking of being anywhere – but Britain – as Ali Lyon reports (July 29, 2025).Facing low pay and rising rents, a quarter of young Brits weigh UK exitThan

GLOBAL TRADE WAR

An important analysis:The global trade war has just startedPresident Trump’s ‘Liberation Day’ has triggered a wave of protectionism that may prove difficult to reverseTha

GERMAN RULING ON FOREIGN TAX INCOME ADJUSTMENTS

Deloitte Tax hand reports (May 21, 2025)https://www.taxathand.com/article/38933/Germany/2025/BFH-clarifies-Foreign-Tax-Act-income-adjustment-rule-for-permanent-establishm

GENERAL ANTI-AVOIDANCE REGIMES

A useful roundup:https://www.squirepattonboggs.com/-/media/files/insights/publications/2017/02/general-antiavoidance-regimes-alert.pdfThanks for reading! Subscribe for fr

GAME THEORY AND OPPORTUNITY ANALYSIS Decision makers exhibit category error in strategic analysis. Risk is confused with opportunity.

Game theory matters. It really matters which game the business Agent (corporate or individual) think they are playing.https://pmc.ncbi.nlm.nih.gov/articles/PMC8288874/Tha

FREEDOM OF SPEECH AND ITS RESTRICTIONS

Toby Mendel, Executive Director, Centre for Law and Democracy writes:https://www.law-democracy.org/Thanks for reading! Subscribe for free to receive new posts and support

FLAT TAX PROPOSALS

Gregory Gethard writes for Investopedia (January 31, 2025)Should the U.S. Switch to a Flat Tax?Thanks for reading! Subscribe for free to receive new posts and support my

FEDERAL TAX WARNING

A must-read alarm bells warning by a senior tax analyst. Worth reading in full.I. IntroductionI believe that the state of the federal income tax system1 is poor, and that

FARMER HARMS The UK’s inheritance tax raid on farms

For American farmers:https://www.usda.gov/about-usda/news/press-releases/2025/07/04/secretary-rollins-praises-president-trumps-one-big-beautiful-bill#:~:text=This%20histo

FACTORING UNDER FIRE

STATES REGULATIONSMarija Nicksic, Esq., Associate, Krieg Devault LLP writes:Thanks for reading! Subscribe for free to receive new posts and support my work.Promulgation o

DO TAX HAVENS DIVERT ECONOMIC ACTIVITY?

An important contribution to the ongoing debate about the economics of tax havens.ABSTRACTThanks for reading! Subscribe for free to receive new posts and support my work.

DEBT BOMBS

In May 2025, a stark warning fromhttps://www.pgpf.org/article/the-federal-government-has-borrowed-trillions-but-who-owns-all-that-debt/Thanks for reading! Subscribe for f

CRUMBLING PILLARS

As explained here:What are the OECD Pillar 1 and Pillar 2 international taxation reforms?Thanks for reading! Subscribe for free to receive new posts and support my work.B

CORPORATE FUNDED ASSET TRUSTS An international policy comparison

USACorporate funded asset trusts, also known as business trusts or specialized asset protection trusts (APTs), can have varying tax implications depending on how they are

CONSTITUTIONAL PROTECTION FOR SPEECH CURATING PLATFORMS

EFF reports (July 13, 2024):Platforms Have First Amendment Right to Curate Speech, As We’ve Long Argued, Supreme Court Said, But Sends Laws Back to Lower Court To Decide

CONFLICT FINANCE

Conflict actors must sustain access to financing to maintain their operations. Additionally, the potential for outsiders to profit from conflict can also grow to become a

CHINA’S EVOLVING TAX DISPUTE FRAMEWORK

An important survey of taxation in China:Audit, Assert, Appeal: China’s Evolving Tax Dispute FrameworkBy Abe ZhaoThanks for reading! Subscribe for free to receive new pos

CENTRAL BANK INDEPENDENCE Surfer and Wave?

The IMF thinks it’s a good thing:https://www.imf.org/en/News/Articles/2024/06/17/sp061424-central-bank-independenceThanks for reading! Subscribe for free to receive new p

CAN TRUMP EXEMPT CHARITABLE EXEMPTIONS?

No Legal Basis Seen for Trump’s Threats to Strip ExemptionsPosted on Sep. 19, 2025Thanks for reading! Subscribe for free to receive new posts and support my work.By Kelse

BUSINESS INCORPORATION RELIEF Always be prepared

Many tax regimes around the world encourage transfer of business or assets from an individual to a corporate entity. After all, it is easier for a tax authority to keep t

BRITTLE BRICS

Saahil Menon writes (October 11 2024)How BRICS is collapsing under the weight of its own ambitionThanks for reading! Subscribe for free to receive new posts and support m

BILLIONAIRE BYE BYE

Ali Lyon reports for City AM (July 9. 2025)UK loses more billionaires than any other countryThanks for reading! Subscribe for free to receive new posts and support my wor

ALL IN THE FAMILY Tax reliefs don't drive family formation

US federal tax policy has long supported family formation and sustainability: well up to a point.https://turbotax.intuit.com/tax-tips/family/tax-exemptions-and-deductions

AI TROUBLES

The ABA reports (July 18 2023)https://www.americanbar.org/groups/business_law/resources/business-law-today/2023-july/back-to-the-basics-the-importance-of-understanding-th

ADVERTISING PROHIBITED SPEECH the UK's HMRC publishes censored information

Rule 1 of Fight Club:https://www.goodfon.com/films/wallpaper-boycovskiy-klub-fight-club.htmlThanks for reading! Subscribe for free to receive new posts and support my wor

4CHAN AND 1ST AMENDMENT RIGHTS

The WPIF is founded on the principle of freedom in communication of information and ideas. Being an economics and tax policy platform, WPIF has little to say about Japane