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Richard is a practitioner of vast experience who is also at pains to keep up to date with all developments in tax law whether by way of new legislation or decisions of the Courts and tax tribunals. Thus, he is able to bring to bear on any problem an encyclopaedic knowledge both of the principles of tax law and the relevant technical provisions. Richard is renowned for his constructive approach to tax problems and strives to surmount difficulties by means of practical proposals.
Richard advises in all fields of taxation. Although his co-authorship of Taxation of Companies and Company Reconstructions gives him special prominence in the field of corporate tax, he is equally at home in personal tax matters. Advice on prospective transactions is at the forefront of his practice, but he relishes also tax disputes whether with the tax authorities or in the context of negligence claims. In 2006 he appeared before the Special Commissioners in Noved v HMRC which concerned the question of whether a gift by a company to a charity/ shareholder was a “distribution” under s.209(2)(b), and Rowland v HMRC which turned on whether reliance on the advice of an accountant gave the taxpayer a “reasonable excuse”. In 2004 he appeared in Campbell v IRC (income loss on the disposal of an RDS) which is one of the few instances in recent years in which an aggressive tax scheme has been held to succeed.
Approachable and a team worker
Richard is happy to work as a member of a team, providing leadership as the circumstances require. He is highly proactive and is well known for his pre-consultation e-mails which are aimed at clarifying matters of doubt in advance. Richard is always happy to discuss prospective matters by phone where a view is required on whether something is worth pursuing.
To see Richard's article on HMRC's replacement for IR20, "Does HMRC 6 have the Xfactor?" in September's issue of Tax Adviser click here
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