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Ingenious: genuine trading endeavour or MacGuffin?

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In Ingenious, the Upper Tribunal found that none of the appellant LLPs was trading with a view to profit, partially overturning the decision of the First-tier Tribunal. The LLPs’ activities were found to be speculative investments in financial assets that were made, not to generate profits, but to secure investor tax losses. The decision provides a helpful indication of the factors the courts will consider when determining whether someone is trading with a view to profit. It is unlikely, however, that this decision will be the final word in a dispute which is likely to be appealed further.
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