A letter you weren’t expecting and probably didn’t think was still possible

Next steps:

What this demand is actually about

In broad terms, West 28th Street demands usually involve:

• historic contractor loan or Employee Benefit Trust arrangements
• loans said to remain outstanding
• a third party claiming to have acquired those loans by assignment

Many recipients previously participated in contractor loan or Employee Benefit Trust arrangements, often more than a decade ago. These structures were widely used by contractors in sectors such as IT, engineering and the NHS, sometimes through intermediaries or tax advisers, who promoted these schemes as means of reducing tax liabilities.

While the tax treatment of those arrangements has already been addressed with HMRC, what you are now facing is different, because West 28th Street is not the same as HMRC, and not the original lender. West 28th Street claims to have acquired alleged loan balances by assignment and is now seeking repayment from individuals.

Also, it is important to understand that a letter of demand is not a court judgment, and the fact that a claim is being asserted does not mean it will ultimately succeed. There may be valid reasons for you to oppose the demand.

Is there any basis to avoid paying the sums demanded of me? 

Similar loan repayment demands have been made in the past, under different company names. Those attempts raised similar legal questions and, in most cases, where promptly resisted, did not progress beyond the early stages of litigation. 

The revival of claims following assignment does not remove the underlying issues. In appropriate cases, there may be prospective defences, including questions around: 

• enforceability
• assignment
• limitation
• documentation
• prior enforcement history 

Whether any of those apply depends on the detail. That is why early, informed legal advice is important. 

Ignoring a demand rarely helps. Silence or an ill‑judged response can later be relied on in court and may limit the legal options available to you. 

If you’ve received a demand and are unsure what to do next, you can call us or submit an online enquiry. 

Why Greenwoods?

We understand how unsettling it is to receive a legal demand out of the blue, particularly where it relates to arrangements entered into many years ago and which you may have thought were long behind you. 

We are a specialist disputes team with extensive experience advising on complex, long‑running disputes arising out of historic tax planning and remuneration structures. These claims often involve incomplete documentation, revived enforcement attempts and the need for a coordinated response across large numbers of affected individuals. 

Our Disputes team is led by Huw Wallis, Head of Disputes, and supported by Partner, Euan Palmer, who has recent experience successfully concluding large‑scale group litigation against HMRC on behalf of more than 80 individuals. Together, they combine senior strategic oversight with hands‑on management of complex factual detail. 

We are used to acting where: 

• claims surface many years after the original arrangements
• rights have been assigned or enforcement revived
• multiple individuals are affected, but positions differ
• a proportionate, coordinated strategy is required 

Clients who work with our Disputes team often describe the experience in these terms: 

“The most supportive solicitor team I have ever worked with.”
“Pragmatic, responsive and genuinely sensitive to the requirements of clients.”
“Huw and the team show real attention to detail and emotional intelligence, alongside high‑quality strategic advice.” 

Our focus is not on alarmism or assumptions. It is on helping you understand where you stand and supporting you through what can otherwise feel like an overwhelming situation. 

Acting together where it makes sense 

Many West 28th Street demands are issued at scale, often to hundreds or thousands of individuals at the same time. While everyone’s position needs to be assessed on its own facts, there are often real advantages in approaching these claims in a coordinated way. 

Where appropriate, we help individuals act together rather than in isolation. This allows common issues to be identified, strategy to be aligned, and costs to be managed proportionately – while still advising each person on their own specific position. 

In practice, this can involve establishing a Management Board structure, where representatives of affected individuals help shape overall strategy, supported by our disputes team. This is not a one‑size‑fits‑all approach, and it is not right in every case – but where it is appropriate, it can be a powerful way of dealing with large‑scale claims calmly and efficiently. 

Clients often tell us that knowing they are not dealing with the situation alone is one of the most reassuring aspects of this approach. 

If you know others who have received similar demands and are unsure what to do, you are very welcome to share our details with them. Many people first contact us after speaking to someone else in the same position, and we are always happy to have an initial conversation to explain how we can help. 

How it works

After the initial call or online enquiry, we make it straightforward to share what we need through a secure client portal.