In Schofield v HMRC (Upper Tribunal – 1 August) an individual (S) realised a substantial capital gain in 2002/03 on the disposal of some loan notes.
However in his tax return he claimed that he had made a loss of more than £11 000 000 on the disposal of a ‘put’ option.
He had purchased the option on 7 February 2003 along with a corresponding ‘call’ option and disposed of it on 4 April 2003.
(He disposed of the ‘call’ option on 7 April 2003 by which time he had become resident in Spain so that the gain on this disposal was outside the scope of UK CGT.)
HMRC rejected the claim and S appealed. The First-tier Tribunal dismissed his...
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In Schofield v HMRC (Upper Tribunal – 1 August) an individual (S) realised a substantial capital gain in 2002/03 on the disposal of some loan notes.
However in his tax return he claimed that he had made a loss of more than £11 000 000 on the disposal of a ‘put’ option.
He had purchased the option on 7 February 2003 along with a corresponding ‘call’ option and disposed of it on 4 April 2003.
(He disposed of the ‘call’ option on 7 April 2003 by which time he had become resident in Spain so that the gain on this disposal was outside the scope of UK CGT.)
HMRC rejected the claim and S appealed. The First-tier Tribunal dismissed his...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")