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[jamesbrown]

Unwinding of the Chancellor Millipede short positions....

[jamesbrown]

He will struggle to be more hated than Starmer. His policies will almost certainly be pretty tulipe for a majority here that prefer to keep more of their money and there are not good signs that he will take any politically difficult decisions either, such as ditching the pensions triple lock, increasing...

[jamesbrown]

Well, curiosity and experience are somewhat separate things, but it would depend on the nature of the work and risk involved (which is why this thread often ends up with useless generalisations). To be clear, there's value in all three of education, experience and curiosity, in general, and that should...

[jamesbrown]

I think there's truth in both, actually. A degree is not worthless, it provides foundational knowledge that you often will not pick up (as easily/quickly/correctly) if you experience it indirectly or try to learn it yourself. At the same time, for literally any trade/profession that ever existed, caring...

[jamesbrown]

Not to completely dissuade you from a B2B relationship, especially because my experience is in the other direction (i.e. U.S. clients, rather than subbing work to the US), but I think your compliance risk goes to the moon with this approach. You could realistically create a PE or disguised employment...

[jamesbrown]

I literally would've put money on you responding with something like this, mal

I can't see myself voting for the Tories while Badenoch is leading and Mel Stride is shadow chancellor. Badenoch just isn't very well suited for leadership IMHO - the pantomime of PMQs is totally unimportant...

[jamesbrown]

I would like to see a right-of-centre party that is not the Tory party (who can feck right off) with a credible plan for gov't, but the Farage clownshoe is definitely not that thing, just as the Polanski clownshoe is not that thing for lefties. Farage is a good campaigner, but just doesn't have the...

[jamesbrown]

It's just another example of over-complicating rather than simplifying. For example, consider people that have PAYE income that fluctuates or is much smaller than an amount that could be collected that way. Isn't that why you can only currently do this if the amount is less than £3k (i.e., opt for...

[jamesbrown]

Largely unrelated (focused on LLPs, but pushing in the same general direction w/r to more people on the payroll), but this one just finished in the SC, around 5 years after the FTT in 2021, so 2031 is not ridiculous:

https://www.cityam.com/hedge-fund-ru...-financier-los...

[jamesbrown]

The "cash-like" definition definitely covers money market funds, but only 100% investments in them So, as I understand it, you could have 99.9% in a MMF and 0.1% in, say, gold, and you'd be fine. This (among other reasons) is why the industry is pointing and laughing. It is such a classic...

[jamesbrown]

This is all pre-emptive "big brain" because the £12k limit and associated tax on cash-like investments doesn't kick in until next year. There is no existing loophole, other than low-risk investments currently being available within S&S ISA wrappers. They were simply trying to get more...

[jamesbrown]

Handy Kafkaesque word map:

• Simplification: easier for us to collect tax from baddies*
• Fairness: more tax from baddies*

*you...

[jamesbrown]

Exactly this. It really isn't much different than any other legal hearing in that regard. It is a structural artifact of being an adversarial legal system where you literally advocate, especially in your closing statement, you don't provide a balanced view. If you've never witnessed that before, I can...

[jamesbrown]

My reading is that yup29 paid the full amount of outstanding tax under the deemed payment calculation (plus the separate fine to CH for the unrelated failures) and HMRC considered that to be "good faith" () and "allowed" the statutorily required offsets to be applied against...

[jamesbrown]

Denying, they simply cannot do for a timely request because that is explicitly legislated against (specifically, w/r to taxes on distributions like dividends in Chapter 9, but there is similar/general legislation for other taxes, notably CT). Delay (and even lies about denying) is a different matter,...

[jamesbrown]

Yes, it is/was relatively common for an accountant to set up the company, just not great. However, the major red flag was the tax loss insurance due to the way the legislation is worded, but this definitely isn't the same risk with regular business insurance - it isn't a great look, tbh, but not an...

[jamesbrown]

There are a couple of red flags there, tbh. Accountant creating the company. Accountant providing tax loss insurance. The latter is a big red flag given the wording of ITEPA Ch. 9:



I don't think either of CK or Boox did that. If Crunch are or were doing that, and you have...

[jamesbrown]

I understand the concern, but you shouldn't get overly worried about this. HMRC is taking its usual hardline position, which is theatre. Even if the case is lost (still unlikely in my view) and there is an eventual tax debt, it is within the remit of a tribunal judge to issue a binding direction about...

[jamesbrown]

I think you are severely overestimating Milan's abilities. I mean, he purchased a Porsche that isn't a 911....

[jamesbrown]

+1 for no accountants (well, no accountants plus some personal competence), but also +1 for not getting too excited about the summing up from HMRC barristers, it is a completely unconstrained sales pitch. As you say, the implications of a resounding loss would be severe and broad, far beyond the scope...