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Legal 500, 2018

25 March 2015

UT Decision: Malcolm Healey v HMRC

INCOME TAX — floating rate notes stripped of intermediate interest coupons — whether difference between purchase price when coupons stripped and sale price when remaining coupons to redemption re-attached a capital or income gain — income — whether a “discount” within Schedule D Case III — yes — appeal dismissed

Kevin Prosser QC & Charles Bradley, instructed by Hotham Services Ltd, acted for the Appellant.

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