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2 Graeme, aged 57, is married to Catherine, aged 58. They work as medical consultants, and both are higher rate
taxpayers. Barry, their son, is aged 32. Graeme, Catherine and Barry are all UK resident, ordinarily resident and
domiciled. Graeme has come to you for some tax advice.
Graeme has invested in shares for some time, in particular shares in Thistle Dubh Limited. He informs you of the
following transactions in Thistle Dubh Limited shares:
(i) In December 1986, on the death of his grandmother, he inherited 10,000 ￡1 ordinary shares in Thistle Dubh
Limited, an unquoted UK trading company providing food supplies for sporting events. The probate value of the
shares was 360p per share.
(ii) In March 1992, he took up a rights issue, buying one share for every two held. The price paid for the rights
shares was ￡10 per share.
(iii) In October 1999, the company underwent a reorganisation, and the ordinary shares were split into two new
classes of ordinary share – ‘T’ shares and ‘D’ shares, each with differing rights. Graeme received two ‘T’ and three
‘D’ shares for each original Thistle Dubh Limited share held. The market values for the ‘T’ shares and the ‘D’
shares on the date of reorganisation were 135p and 405p per share respectively.
(iv) On 1 May 2005, Graeme sold 12,000 ‘T’ shares. The market values for the ‘T’ shares and the ‘D’ shares on that
day were 300p and 600p per share respectively.
(v) In October 2005, Graeme sold all of his ‘D’ shares for ￡85,000.
(vi) The current market value of ‘T’ shares is 384p per share. The shares remain unquoted.
Graeme and Catherine have owned a holiday cottage in a remote part of the UK for many years. In recent years, they
have used the property infrequently, as they have taken their holidays abroad and the cottage has been let out as
furnished holiday accommodation.
Graeme and Catherine are now considering selling the UK country cottage and purchasing a holiday villa abroad.
Initially they plan to let this villa out on a furnished basis, but following their anticipated retirement, would expect to
occupy the property for a significant part of the year themselves, possibly moving to live in the villa permanently.
Required:
(a) Calculate the total chargeable gains arising on Graeme’s disposals of ‘T’ and ‘D’ ordinary shares in May and
October 2005 respectively. (7 marks)
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更多 “ 2 Graeme, aged 57, is married to Catherine, aged 58. They work as medical consultants, and both are higher ratetaxpayers. Barry, their son, is aged 32. Graeme, Catherine and Barry are all UK resident, ordinarily resident anddomiciled. Graeme has come to you for some tax advice.Graeme has invested in shares for some time, in particular shares in Thistle Dubh Limited. He informs you of thefollowing transactions in Thistle Dubh Limited shares:(i) In December 1986, on the death of his grandmother, he inherited 10,000 ￡1 ordinary shares in Thistle DubhLimited, an unquoted UK trading company providing food supplies for sporting events. The probate value of theshares was 360p per share.(ii) In March 1992, he took up a rights issue, buying one share for every two held. The price paid for the rightsshares was ￡10 per share.(iii) In October 1999, the company underwent a reorganisation, and the ordinary shares were split into two newclasses of ordinary share – ‘T’ shares and ‘D’ shares, each with differing rights. Graeme received two ‘T’ and three‘D’ shares for each original Thistle Dubh Limited share held. The market values for the ‘T’ shares and the ‘D’shares on the date of reorganisation were 135p and 405p per share respectively.(iv) On 1 May 2005, Graeme sold 12,000 ‘T’ shares. The market values for the ‘T’ shares and the ‘D’ shares on thatday were 300p and 600p per share respectively.(v) In October 2005, Graeme sold all of his ‘D’ shares for ￡85,000.(vi) The current market value of ‘T’ shares is 384p per share. The shares remain unquoted.Graeme and Catherine have owned a holiday cottage in a remote part of the UK for many years. In recent years, theyhave used the property infrequently, as they have taken their holidays abroad and the cottage has been let out asfurnished holiday accommodation.Graeme and Catherine are now considering selling the UK country cottage and purchasing a holiday villa abroad.Initially they plan to let this villa out on a furnished basis, but following their anticipated retirement, would expect tooccupy the property for a significant part of the year themselves, possibly moving to live in the villa permanently.Required:(a) Calculate the total chargeable gains arising on Graeme’s disposals of ‘T’ and ‘D’ ordinary shares in May andOctober 2005 respectively. (7 marks) ” 相关考题
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Mum: Susan, come and meet aunt Amy’s daughter, Catherine.Susan: Hi, Catherine, nice to meet you.Catherine:().
A、Yes.B、Fine, thank you.C、Nice to meet you, too.D、It’s my pleasure.
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(b) Explain the capital gains tax (CGT) and inheritance tax (IHT) implications of Graeme gifting his remaining ‘T’ordinary shares at their current value either:(i) to his wife, Catherine; or(ii) to his son, Barry.Your answer should be supported by relevant calculations and clearly identify the availability and effect ofany reliefs (other than the CGT annual exemption) that might be used to reduce or defer any tax liabilitiesarising. (9 marks)
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4 Assume today’s date is 5 February 2006.Joanne is 37, she was born and until 2005 had lived all her life in Germany. She recently married Fraser, aged 38,who is a UK resident, but who worked briefly in Germany. They have no children.The couple moved to the UK to live permanently on 9 October 2005. Joanne was employed by an American companyin Germany, and she continued to work for them in the UK until the end of November 2005. Her earnings from theAmerican company were ￡5,000 per month. Joanne has not remitted any of the income she earned in Germany priorto her arrival in the UK.Joanne resigned from her job at the end of November 2005. The company did not hold her to the three months noticestipulated in her contract, but still paid her for that period. In total, Joanne paid ￡4,200 in UK income tax under PAYEfor the tax tear 2005/06.Joanne also wishes to sell the shares she holds in a German listed company. The shareholding cost the equivalent of￡3,500 in September 1986, and its current value is ￡21,500. She intends to sell the shares in March 2006 and toinvest the proceeds from the sale in the UK. Joanne has made no other capital disposals in the year.Prior to her leaving employment, Joanne investigated the possibility of starting her own business providing a Germantranslation service for UK companies, and took some advice on the matter. She paid consultancy fees of ￡5,000(excluding value added tax (VAT)) and bought a computer for ￡2,000 (excluding VAT), both on 23 October 2005.Joanne started trading on 1 December 2005. She made sales of ￡2,000 in December, and estimates that her saleswill rise by ￡1,000 every month to a maximum of ￡7,000 per month. Joanne believes that her monthly expenses of￡400 (excluding VAT) will remain constant. Her year end will be 31 March, and the first accounts will be drawn upto 31 March 2006.Although Joanne has registered her business for tax purposes with the Revenue, she has not registered for VAT andis unsure what is required of her in this respect.Required:(a) State, giving reasons, whether Joanne will be treated as resident or non-resident in the UK for the year ofassessment 2005/06, together with the basis on which her income and gains of that year will be subject toUK taxation. (3 marks)
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1 Alvaro Pelorus is 47 years old and married to Maria. The couple have two children, Vito and Sophie, aged 22 and19 years respectively. Alvaro and Maria have lived in the country of Koruba since 1982. On 1 July 2005 the familymoved to the UK to be near Alvaro’s father, Ray, who was very ill. Alvaro and Maria are UK resident, but not ordinarilyresident in the tax years 2005/06 and 2006/07. They are both domiciled in the country of Koruba.On 1 February 2007 Ray Pelorus died. He was UK domiciled, having lived in the UK for the whole of his life. For thepurposes of inheritance tax, his death estate consisted of UK assets, valued at ￡870,000 after deduction of allavailable reliefs, and a house in the country of Pacifica valued at ￡94,000. The executors of Ray’s estate have paidPacifican inheritance tax of ￡1,800 and legal fees of ￡7,700 in respect of the sale of the Pacifican house. Ray leftthe whole of his estate to Alvaro.Ray had made two gifts during his lifetime:(i) 1 May 2003: He gave Alvaro 95 acres of farm land situated in the UK. The market value of the land was￡245,000, although its agricultural value was only ￡120,000. Ray had acquired the land on1 January 1996 and granted an agricultural tenancy on that date. Alvaro continues to own theland as at today’s date and it is still subject to the agricultural tenancy.(ii) 1 August 2005: He gave Alvaro 6,000 shares valued at ￡183,000 in Pinger Ltd, a UK resident tradingcompany. Gift relief was claimed in respect of this gift. Ray had acquired 14,000 shares inPinger Ltd on 1 April 1997 for ￡54,600.You may assume that Alvaro is a higher rate taxpayer for the tax years 2005/06 and 2006/07. In 2006/07 he madethe following disposals of assets:(i) On 1 July 2006 he sold the 6,000 shares in Pinger Ltd for ￡228,000.(ii) On 1 September 2006 he sold 2,350 shares in Lapis Inc, a company resident in Koruba, for ￡8,270. Alvarohad purchased 5,500 shares in the company on 1 September 2002 for ￡25,950.(iii) On 1 December 2006 he transferred shares with a market value of ￡74,000 in Quad plc, a UK quoted company,to a UK resident discretionary trust for the benefit of Vito and Sophie. Alvaro had purchased these shares on1 January 2006 for ￡59,500.Alvaro has not made any other transfers of value for the purposes of UK inheritance tax. He owns the family housein the UK as well as shares in UK and Koruban companies and commercial rental property in the country of Koruba.Maria has not made any transfers of value for the purposes of UK inheritance tax. Her only significant asset is thefamily home in the country of Koruba.Alvaro and his family expect to return to their home in the country of Koruba in October 2007 once Ray’s affairs havebeen settled. There is no double taxation agreement between the UK and Koruba.Required:(a) Calculate the inheritance tax (IHT) payable as a result of the death of Ray Pelorus. Explain the availabilityor otherwise of agricultural property relief and business property relief on the two lifetime gifts made by Ray.(8 marks)
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3 Spica, one of the director shareholders of Acrux Ltd, has been in dispute with the other shareholders over plans toexpand the company’s activities overseas. In order to resolve the position it has been agreed that Spica will sell hershares back to the company. Once the purchase of her shares has taken place, the company intends to establish anumber of branches overseas and acquire a shareholding in a number of companies that are resident and trade inoverseas countries.The following information has been obtained from client files and meetings with the parties involved.Acrux Ltd:– An unquoted UK resident company.– Share capital consists of 50,000 ordinary shares issued at ￡1·90 per share in July 2000.– None of the other shareholders has any connection with Spica.The purchase of own shares:– The company will purchase all of Spica’s shares for ￡8 per share.– The transaction will take place by the end of 2008.Spica:– Purchased 8,000 shares in Acrux Ltd for ￡2 per share on 30 September 2003.– Has no income in the tax year 2008/09.– Has chargeable capital gains in the tax year 2008/09 of ￡3,800.– Has houses in the UK and the country of Solaris and divides her time between them.Investment in non-UK resident companies:– Acrux Ltd will acquire between 15% and 20% of each of the non-UK resident companies.– The companies will not be controlled foreign companies as the rates of tax in the overseas countries will bebetween 23% and 42%.– There may or may not be a double tax treaty between the UK and the overseas countries in which the companiesare resident. Where there is a treaty, it will be based on the OECD model treaty.– None of the countries concerned levy withholding tax on dividends paid to UK companies.– The directors of Acrux Ltd are concerned that the rate of tax suffered on the profits of the overseas companieswill be very high as they will be taxed in both the overseas country and in the UK.Required:(a) (i) Prepare detailed calculations to determine the most beneficial tax treatment of the payment Spica willreceive for her shares; (7 marks)
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(b) Provide the directors of Acrux Ltd with a detailed explanation of the maximum rate of tax that will be sufferedon both the distributed and non-distributed profits of the non-UK resident investee companies where:(1) there is a double tax treaty between the UK and the country in which the individual companies areresident; and(2) there is no such double tax treaty.Note: you are not required to explain the position of the overseas resident branches. (6 marks)
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A middle-aged man might want to see himself as a strong, attractive athlete, which means ().A、All middle-aged men are in good physical health.B、Men also hope to have a beautiful and strong appearance.C、Men usually want to look as attractive as possible.D、Older men should all get exercise in the gym.
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some seats on the bus are ____ reserved for the aged and disabled.
A. extraordinarilyB. intensivelyC. extensivelyD. exclusively
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Instagram, understood by young people, all the young people use Instagram in U.N., mainly aged 18－29 years old, of which men use Instagram more time than women。()
此题为判断题(对，错)。
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Which indefinite article "a" should be read emphatically in the following sentences
A.He is a handsome boy, but not smart.
B.He is not a suspect, he is the suspect.
C.He bought a cartoon book for his son.
D.He is talking with a middle-aged man.
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I have decided to accompapy my aged mother this summer to visit France,which is one of her lifelong dreams.A:accommodate
B:take
C:escort
D:present
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Which group of people cannot vote in the general election?（）AMembers in the House of Commons.BLords in the House of Lords.CThe UK citizens above the age of 18.DThe UK resident citizens of the Irish Republic.
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Prescription charges do not apply to the following people except（）Aself-employed peopleBchild under 16Cwar and armed forces disablement pensionersDwomen aged 60 and over and men aged 65 and over
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Which file characteristic cannot be used in the Cisco IronPort Data Security policies？（） A、 file typeB、 file sizeC、 file ageD、 file name
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单选题The middle-aged man was seen _____ out of the house on the afternoon of the murder.A
cameB
comeC
to comeD
have come
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单选题Which group of people cannot vote in the general election?（）A
Members in the House of Commons.B
Lords in the House of Lords.C
The UK citizens above the age of 18.D
The UK resident citizens of the Irish Republic.
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单选题What might prevent Mary, aged 25, becoming a babysitter?A
She once broke a traffic law and was fined.B
She has never worked as a babysitter before.C
She can’t speak Japanese very well.
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单选题He ______ it, but he used his experiences in his writing. He married Catherine Hogarth and they had a big family.A
hatedB
enjoyedC
wantedD
shamed
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单选题Prescription charges do not apply to the following people except（）A
self-employed peopleB
child under 16C
war and armed forces disablement pensionersD
women aged 60 and over and men aged 65 and over
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单选题Which indefinite article a should be read emphatically in the following sentences?A
He is a handsome boy, but not smart.B
He is not a suspect, he is the suspect.C
He bought a cartoon book for his son.D
He is talking with a middle-aged man.
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单选题The sentence “In Kids Country we do not permit middle-aged” underlined in Paragraph 2 means that middle-aged .A
are not permitted to live in AmericaB
are not welcome in AmericaC
become old too quicklyD
have already been overtaken by children
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单选题This aged patient complied with the physician’s orders, hoping for a quick recovery.A
obeyedB
defiedC
memorizedD
contemplated
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