来了解关于国际注册会计师考试难度是怎么样的？

正确答案：
(d) Stuart is not making use of his nil rate band, as all assets are transferred, exempt from inheritance tax (IHT), to Rebecca (as
spouse) on death. He should consider altering his will to transfer an amount equivalent to the nil rate band to his son, Sam.
If Stuart dies before altering his will, Rebecca can elect to make a Deed of Variation in favour of Sam instead. This will have
the same effect as the above.
Care should be taken in determining which assets are subject to this legacy. The Omega plc shares should not be transferred
to Sam as they currently attract 50% BPR. Instead, assets not subject to any reliefs (such as the insurance payout or cash
deposits) should be used instead. By doing this, IHT of ￡105,200 (￡263,000 x 40%) could be saved on the ultimate death
of Rebecca.
It is too late for Stuart to make use of potentially exempt transfers (PETs) as no relief is obtained until three years have passed,
and full relief only occurs seven years after making the gifts. The same would also apply to Rebecca if she were to die on 1
March 2008. However, as she is currently in good health, she may decide to make lifetime gifts, although she should also
not gift the Omega plc shares for the reasons stated above as any gift other than of the entire holding will result in the loss
of BPR on the remainder.
Both individuals should make use of their annual exemptions (￡3,000 per person per year). The annual exemptions not used
up in the previous year can be used in this current year. This would give a saving of ￡2,400 each (3,000 x 2 x 40%).
Exemptions for items such as small gifts (￡250 per donee per year) are also available.
Gifts out of normal income should also be considered. After making such gifts, the individual should be left with sufficient
income to maintain their usual standard of living. To obtain the exemption, it is usually necessary to demonstrate general
evidence of a prior commitment to make the gifts, or a settled pattern of expenditure.
While there are no details of income, both Stuart and Rebecca are wealthy in their own right, and are likely to earn reasonable
sums from their investments. They should therefore be able to satisfy the conditions on that basis.
If Rebecca were to make substantial lifetime gifts, the donees would be advised to consider taking out insurance policies on
Rebecca’s life to cover the potential tax liabilities that may arise on any PETs in the event of her early death.
Tutorial note: the answer has assumed that the shares could be bought for ￡2·10, their value for IHT.

正确答案：
(ii) Tax-free accommodation
It is not possible for Messier Ltd to provide Galileo with tax-free accommodation. The provision of accommodation by an
employer to an employee will give rise to a taxable benefit unless it is:
– necessary for the proper performance of the employee’s duties, e.g. a caretaker; or
– for the better performance of the employee’s duties and customary, e.g. a hotel manager; or
– part of arrangements arising out of threats to the employee’s security, e.g. a government minister.
As a manager of Messier Ltd Galileo is unable to satisfy any of the above conditions.

正确答案：
(b) Negotiated transfer prices suffer from the following limitations:
– The transfer price which is the final outcome of negotiations may not be close to the transfer price that would be optimal
for the organisation as a whole since it can be dependent on the negotiating skills and bargaining powers of individual
managers.
– They can lead to conflict between divisions which may necessitate the intervention of top management to mediate.
– The measure of divisional profitability can be dependent on the negotiating skills of managers who may have unequal
bargaining power.
– They can be time-consuming for the managers involved, particularly where large numbers of transactions are involved.