In M Healey v HMRC (TC02591 – 19 March) an individual (H) purchased certain floating rate notes marketed by a bank and described as ‘flexi-notes’ which had been stripped of interest for a certain period. At the end of the period H sold the notes making a total profit of £8 680 000. HMRC issued amendments to H’s self-assessment treating the profits which he had made on the sale of the notes as discounts which were chargeable to income tax under what is now ITTOIA 2005 s 381. H appealed contending that the flexi-notes were qualifying corporate bonds and that his profits were capital rather than income. The First-tier Tribunal rejected this contention and dismissed H’s appeal applying the principles laid down by the HL in the 1921 case of National Provident Institution v Brown (8 TC 57). Sir Stephen Oliver...
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In M Healey v HMRC (TC02591 – 19 March) an individual (H) purchased certain floating rate notes marketed by a bank and described as ‘flexi-notes’ which had been stripped of interest for a certain period. At the end of the period H sold the notes making a total profit of £8 680 000. HMRC issued amendments to H’s self-assessment treating the profits which he had made on the sale of the notes as discounts which were chargeable to income tax under what is now ITTOIA 2005 s 381. H appealed contending that the flexi-notes were qualifying corporate bonds and that his profits were capital rather than income. The First-tier Tribunal rejected this contention and dismissed H’s appeal applying the principles laid down by the HL in the 1921 case of National Provident Institution v Brown (8 TC 57). Sir Stephen Oliver...
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