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My fellowship thesis for the Chartered Institute of Taxation

Writing a thesis is a major task, and the document needs to be managed as a whole. My advice is to write everything you want to say, ignoring word count restrictions, and then edit down to the permitted length. Being too conscious of the word count while the thesis is being written will adversely affect the quality.

25 September 2010 Updated 6 February 2016, with minor edits 25 July 2020.

I trained as a chartered accountant with a small firm from 1974 to 1977. While most of the work comprised preparing accounts from incomplete records, staff were also responsible for preparing the tax computation based upon the accounts.

I developed an interest in tax from such computational work. Accordingly, when I qualified as a chartered accountant I decided to specialise in tax as well as moving to an international accounting firm.

The Chartered Institute of Taxation is the only professional body in the United Kingdom devoted solely to the development of the practice of tax. Accordingly, I wanted to join as quickly as possible and successfully took the examinations to become an associate member in April 1978.

At that time, the Institute also had a higher level examination for admission to fellowship. I planned to take the fellowship exam after gaining a few years of practical experience. However, the Institute found the fellowship exams expensive to organise given the small number of candidates. A year so after I became an associate, the fellowship exam was abolished and replaced by admission to fellowship by thesis.

For the next decade and a half, although I was a full-time tax specialist and heavily involved with the Manchester branch of the Institute, I could never think of anything that I wanted to write a thesis upon.

All subjects seemed to fall into two categories:

The starting point for change was the Finance Act 1993, which revised the UK corporate tax law on foreign exchange gains and losses. This led to my taking examinations again after a gap of 17 years when in April 1995 I successfully took the examinations to become an associate member of the Association of Corporate Treasurers.

The following the year, the Finance Act 1996 revised, from the ground up, the UK corporate tax law on debt and interest. It suddenly occurred to me that here was a subject that I was passionately interested in, and on which I could write a thesis without risking a leakage of valuable intellectual property.

With the concurrence of the other partners at Price Waterhouse to whom I reported, I registered my thesis title and a synopsis with the Institute on 10 September 1996. The Institute's rules require the submission of a thesis within three years of registration, but I never expected to take such a long time. Indeed, I put into my partner personal plan that I would submit the thesis by 30 June 1997.

With hindsight, I clearly had no appreciation how difficult it was going to be to find time to progress the thesis. Given the pressures of the working day, only weekends and holidays provided any available time. Progress was made in fits and starts. I.e. for a few weekends consecutively I would spend Sundays working in the office and then another long gap would ensue. When 1999 started, I had about 8,000 words written, all part of the introduction before addressing the FA 1996 changes themselves. I could also see that the deadline was now only nine months away.

By devoting many weekends and virtually all available vacation time from January until the end of August, I managed to get the thesis finished with just two weeks to spare.

The editing process

By the end of May, I had a draft of just under 41,000 words. While the Institute's rules limit the maximum length to 25,000 words, I considered it impossible to write to a set length. Instead, I always planned to write the text I felt appropriate, and then edit it downwards.

Performing the level of surgery required was very difficult. I began by rewriting sentence by sentence to say the same thing with less words. While this reduced the length a bit, I soon realised it was never going to reduce it enough, and that I would need to slash whole sections that I had written as a labour of love. In conversation with friends, I have described it, somewhat colourfully, like "killing your children."

However once I had finished (and it took 15 solid days to do the editing down) I realised that the final shorter result was a much better document than the original. More than anything else in my career, this taught me the importance of focusing on the key content and cutting out everything that is not strictly necessary. I have made my long draft available so that readers who want to can compare it with the final version and see how the cutting process improved the document.

The thesis as finally submitted contained 24,995 words.

Writing to the specified length

In my view, with long documents, it is impossible to produce a good document by writing upwards to the specified length and then stopping.

It hard even for short pieces of a few hundred words. With with a length of say 80,000 words (a typical PhD thesis) I consider it impossible to get the ideas and structure right while also writing the words if you intend to stop when you reach the permitted length.

Hence my approach above of first writing everything I wanted to say, even though that lead to my writing 41,000 words, and then editing downwards to the specified maximum length.

Text of the thesis

The thesis as submitted comprises sections 2 - 11 and 13 of the document which is available below along with the equivalent parts of the table of contents.

Section 1 did not exist of course in the document submitted to the CIOT. The submitted thesis was anonymous, with just a reference number to identify it so that referees were not influenced by any knowledge about the writer.

The legislation it referred to has changed very significantly since 1999. For the convenience of readers who do not have the legislation readily to hand, in either its current or 1999 version, I have included in section 12 almost all of the legislation mentioned in this document as it stood in 1999. As the tax law has changed so much since then, I suggest taking the following approach to reading the thesis:

Apart from the actual content, the thesis may also be useful as a specimen for how to tackle the need to write a thesis, and how to handle complex documents in Microsoft Word. Accordingly, as well as the PDF version of my FTII thesis, I have also made the Word version available on this website.

Article in "Tax Adviser" magazine

"Tax Adviser" is the house magazine of the Chartered Institute of Taxation. To encourage other associates to seek fellowship by thesis, the editor asked if I could write an article "Becoming a fellow" about what prompted me to write the thesis and how I found the experience. I was happy to oblige, but was perhaps too honest.

Shortly after the article was published, one of my clients read it and told me that after reading it he was certain that he never wanted to write a fellowship thesis!

The article also gave practical advice about how I narrowed the specification for the thesis, and how I went about doing the research and tackled writing such a long document. The thesis remains the longest thing I have written so far.

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