Any profits from underwriting issues of shares, including those
of a casual nature, are liable to tax Lyons v Cowcher [1926]
10TC438.
A financial concern assessed under Case I should include any
profits from underwriting in the computation of its trading
profits.
If any other person acts as underwriter on a number of
occasions, they may be regarded as carrying on a trade of
underwriter. See
BIM20235 for further guidance on this
point.
In any other case, the profits should be treated as Case VI
income.
