Michael has taught students for the LLM in International Tax at Kings since 2017. He teaches on campus and also teaches part of the online LLM. His main focus is on the UK taxation of business enterprises (unincorporated and incorporated) as well as aspects of EU Tax Law (such as the harmonisation and Anti-Tax Avoidance Directives). Michael also teaches at the Universities of Oxford and Amsterdam in relation to the taxation of trusts, especially where this involves double tax treaty and entity classification issues. For many years, Michael was a UK tax partner in major international law firms and still practises part-time as a senior tax adviser, having worked recently for major London-based law firms and a "Big Four" accounting firm. He has lived and worked abroad as a practising lawyer (Paris and New York). Michael speaks and reads French (including legal French) fluently. His German is also quite fluent. 

He graduated with two first class law degrees (BA and BCL) from the University of Oxford in 1985 and 1987. His BA result was the second highest in 1985. In 2021, he was a awarded a PhD in law by the Vrije Universiteit van Amsterdam, having been supervised by Dr John Avery Jones CBE and Professor Frank Potgens. In 2024, he was awarded a Fellowship of the UK Chartered Institute of Taxation, on the basis of the book he published in 2023 following his PhD thesis. In his spare time, he enjoys hill walking, running, skiing, travel, reading history and playing the piano. He has three daughters (age range 8 to 30).

Research interests 

Michael has researched, and written extensively in relation to tax law for over thirty years, as his list of publications makes clear. His main interests relate to corporate taxation (not limited to UK taxation), and especially its international and comparative aspects e.g. EU tax law, issues involving double tax treaties and the OECD's Pillar 1 and 2 projects for taxing the digital economy and creating a corporate minimum tax. He has spoken about tax matters at many conferences all over the world, both as a practitioner and an academic. More recently, he has taken a close interest in the international taxation of wealth preservation structures (especially trusts and foundations). This overlaps with his other main area of research focus: the classification of entities for tax purposes and the problems to which this gives rise, especially in relation to cross-border taxation.

Teaching interests 

• Corporate taxation, especially as it relates to cross-border transactions and structures
• International taxation of private wealth preservation structures
• Aspects of EU tax law

Selected publications 

1. “Pigott (Inspector of Taxes) v Staines Investments Ltd”. Case note - [1995] British Tax Review 411.
2. “The United Kingdom: Tax Considerations for US Acquirors of UK Companies”. Tax Notes International. October 1997, page 1199.
3. “Inland Revenue’s Transfer Pricing Enforcement Options: Updated Transfer Pricing Rules and a new APA procedure.” Special Report – Tax Management BNA 2000.
4. “A guide to European Holding Companies: the UK”. Journal of International Taxation. March 2001, page 20.
5. “UK Restrictions on the use of Dual Consolidated Losses”. Tax Notes International, March 2004, page 903.
6. “Ongoing Uncertainty regarding Entity Classification for UK Tax Purposes”. Journal of Taxation of Investments (Summer 2010, page 77).
7. “Investment in the UK: Some New Clarification on Tax Avoidance Issues but some points still unclear”. Journal of Taxation of Investments (Fall 2011, page 59).
8. “The European Commission Draft Directive on Financial Transactions Tax and its implications”. Journal of Taxation of Investments (Winter 2012, page 83).
9. “UK Enacts Tax Regime for New Additional Tier 1 and Tier 2 Regulatory Capital Instruments”. Journal of Taxation of Investments (Summer 2014, page 81).
10. “The New UK Bank Levy”. Journal of Taxation of Investments (Fall 2010, page 33).
11. “European Commission v Portuguese Republic: implications for exit taxes in the EU”. Case note - [2013] British Tax Review 530.
12. “Section 229 and Schedule 49: corporation tax – deferral of payment of exit charge – corporate exit charges and EU law”. Case note – [2013] British Tax Review 542.
13. “SCA Group Holding BV, X AG and others, and MSA International Holdings BV and another: the CJEU considers the impact of EU law on the scope of tax groups or fiscal unities”. Case note – [2014] British Tax Review 530.
14. “Autogrill Espana SA v European Commission; and Banco Santander SA and Santusa Holding SL v European Commission: Spanish tax rules, state aid and ‘selective advantage’”. Case note – [2015] British Tax Review 13.
15. Taxation Chapter (Co-author). “Restructuring Law and Practice” (2^nd edition - 2015). Hedger and Howard. Lexis Nexis.
16. “HMRC v Lloyds Bank leasing (No 1) Ltd: the troublesome increase in the scope of the ‘sole or main object’ test”. Case note – [2015] British Tax Review 649.
17. “Airtours Holidays Transport Ltd v HMRC: to whom has a supply been made for VAT purposes?” Case note – [2016] British Tax Review 449.
18. “Cross-Border Investments: HMRC responds to UK Supreme Court Ruling that a Delaware LLC is ‘Tax-Transparent’ ”. Journal of Taxation of Investments (Winter 2016, page 59).
19. “Classifying Entities and the Meaning of ‘Tax Transparency’ – the UK Perspective”, Kluwer Law International, 2023. Book based on PhD thesis “The classification of entities, and the meaning of ‘tax transparency” in United Kingdom tax law”, submitted successfully at the Vrije Universiteit van Amsterdam in March 2021[2].
20. Chapter 10: “Corporate Taxation in the UK”, in “Research Handbook on Corporate Taxation” ed. Reuven S. Avi-Yonah, Edward Elgar Publishing Ltd, 2023.
21. “BCM Cayman LP v HMRC: partnerships as members of other partnerships”. Case note - [2024] British Tax Review 190.
22. “HMRC v Bluecrest Capital Management LP; Andrew Dodd v HMRC: partnership profits and ‘miscellaneous income’”. Case note - [2024] British Tax Review 199.
23. Chapter 16: “United Kingdom”, in “Taxation of International Partnerships” (2^nd edition – 2025) ed. Prof. Dr Florian Haase. International Bureau of Fiscal Documentation, 2025.
24. “The Resilience, and Continued Relevance of the Rule in Baker v Archer-Shee”. Peer-reviewed article - [2025] British Tax Review 255.
25. “The UK income tax treatment of individual members of a UK limited liability partnership: HMRC v Bluecrest Capital Management (UK) LLP”. Case note - [2025] British Tax Review 324. 
26. Chapter 7: “Tax Treaty Conflicts in relation to attributing trust income and the vexed issue of beneficial ownership as it relates to trusts”, in “Taxation of Trusts, Foundations and Similar Arrangements in a Global Setting, ed. Prof. Dr Andres Baez Moreno, Dr Mario Tenore, Prof. Dr Vikram Chand and Dr Svetislav V. Kostic. Kluwer Law International, 2025. 

[1] A number of the journal articles listed above were produced with the help of junior colleagues whose contribution is gratefully acknowledged. In those cases, and with the exception of Item 8, I was the primary author.

[2] This was based in part on a unpublished paper (“Entity Classification under UK Law, with particular reference to the UK—US double tax treaty) which I produced in November 1994 for the Princeton Tax Club, New York.