Chancery Division.

[The appeal against this decision is reported at [1998] BTC 466.]

Robert Walker J.

Judgment delivered 7 March 1997.

Corporation tax – Allowable loss – Loan in US dollars by UK company to US member of group secured on real property – Promissory note given as security – Currency conversion loss – Whether loss in respect of a debt on a security – Whether allowable loss – Capital Gains Tax Act 1979, s. 82(3)(b), 134(1) (Taxation of Chargeable Gains Act 1992, s. 132(3)(b), 251(1).

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