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5 Gagarin wishes to persuade a number of wealthy individuals who are business contacts to invest in his company,
Vostok Ltd. He also requires advice on the recoverability of input tax relating to the purchase of new premises.
The following information has been obtained from a meeting with Gagarin.
Vostok Ltd:
– An unquoted UK resident company.
– Gagarin owns 100% of the company’s ordinary share capital.
– Has 18 employees.
– Provides computer based services to commercial companies.
– Requires additional funds to finance its expansion.
Funds required by Vostok Ltd:
– Vostok Ltd needs to raise ￡420,000.
– Vostok Ltd will issue 20,000 shares at ￡21 per share on 31 August 2008.
– The new shareholder(s) will own 40% of the company.
– Part of the money raised will contribute towards the purchase of new premises for use by Vostok Ltd.
Gagarin’s initial thoughts:
– The minimum investment will be 5,000 shares and payment will be made in full on subscription.
– Gagarin has a number of wealthy business contacts who may be interested in investing.
– Gagarin has heard that it may be possible to obtain tax relief for up to 60% of the investment via the enterprise
investment scheme.
Wealthy business contacts:
– Are all UK resident higher rate taxpayers.
– May wish to borrow the funds to invest in Vostok Ltd if there is a tax incentive to do so.
New premises:
– Will cost ￡446,500 including value added tax (VAT).
– Will be used in connection with all aspects of Vostok Ltd’s business.
– Will be sold for ￡600,000 plus VAT in six years time.
– Vostok Ltd will waive the VAT exemption on the sale of the building.
The VAT position of Vostok Ltd:
– In the year ending 31 March 2009, 28% of Vostok Ltd’s supplies will be exempt for the purposes of VAT.
– This percentage is expected to reduce over the next few years.
– Irrecoverable input tax due to the company’s partially exempt status exceeds the de minimis limits.
Required:
(a) Prepare notes for Gagarin to use when speaking to potential investors. The notes should include:
(i) The tax incentives immediately available in respect of the amount invested in shares issued in
accordance with the enterprise investment scheme; (5 marks)
参考答案
更多 “ 5 Gagarin wishes to persuade a number of wealthy individuals who are business contacts to invest in his company,Vostok Ltd. He also requires advice on the recoverability of input tax relating to the purchase of new premises.The following information has been obtained from a meeting with Gagarin.Vostok Ltd:– An unquoted UK resident company.– Gagarin owns 100% of the company’s ordinary share capital.– Has 18 employees.– Provides computer based services to commercial companies.– Requires additional funds to finance its expansion.Funds required by Vostok Ltd:– Vostok Ltd needs to raise ￡420,000.– Vostok Ltd will issue 20,000 shares at ￡21 per share on 31 August 2008.– The new shareholder(s) will own 40% of the company.– Part of the money raised will contribute towards the purchase of new premises for use by Vostok Ltd.Gagarin’s initial thoughts:– The minimum investment will be 5,000 shares and payment will be made in full on subscription.– Gagarin has a number of wealthy business contacts who may be interested in investing.– Gagarin has heard that it may be possible to obtain tax relief for up to 60% of the investment via the enterpriseinvestment scheme.Wealthy business contacts:– Are all UK resident higher rate taxpayers.– May wish to borrow the funds to invest in Vostok Ltd if there is a tax incentive to do so.New premises:– Will cost ￡446,500 including value added tax (VAT).– Will be used in connection with all aspects of Vostok Ltd’s business.– Will be sold for ￡600,000 plus VAT in six years time.– Vostok Ltd will waive the VAT exemption on the sale of the building.The VAT position of Vostok Ltd:– In the year ending 31 March 2009, 28% of Vostok Ltd’s supplies will be exempt for the purposes of VAT.– This percentage is expected to reduce over the next few years.– Irrecoverable input tax due to the company’s partially exempt status exceeds the de minimis limits.Required:(a) Prepare notes for Gagarin to use when speaking to potential investors. The notes should include:(i) The tax incentives immediately available in respect of the amount invested in shares issued inaccordance with the enterprise investment scheme; (5 marks) ” 相关考题
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Passage OneQuestions 21 to 25 are based on the following passage.How often one hears children wishing they were grown up, and old people wishing they were young again. Each age has its pleasures and its pains, and the happiest person is the one who enjoys what each age gives him without wasting his time in useless regrets.Childhood is a time when there are few responsibilities. If a child has good parents, he is well fed, looked after and loved. It is unlikely that he will ever again in his life be given so much without having to do anything in return. In addition, life is always presenting new things to the child-things that have lost their interest for older people because they are too well known. A child finds pleasure in playing in the rain, or in the snow. His first visit to the seaside is a marvelous adventure．But a child has his pains：he is not so free to do as he wishes as he thinks older people are; he is continually being told what to do and what not to do．Therefore, a child is not happy as he wishes to be.When the young man starts to earn his own living, he becomes free from the discipline of school and parents; but at the same time he is forced to accept．responsibilities. With no one to pay for his food, his clothes, or his room, he has to work if he wants to live comfortably. If he spends most of his time playing about in the way that he used to as a child, he will go hungry. And if he breaks the laws of society as he used to break the laws of his parents, he may get himself into trouble. If, however, he works hard, goes by the law and has good health, he may feel satisfied in seeing himself make steady progress in his job and in building up for himself his own position in society.Old age has always been thought of as the worst age to be; but it is not necessary for the old to be unhappy. With old age comes wisdom and the ability to help others with advice wisely given. The old can have the joy of seeing their children making progress in life; they can watch their grandchildren growing up around them; and, perhaps best of all, they can, if their life has been a useful one, feel the happiness of having come through the battle of life safely and of having reached a time when they can lie back and rest, leaving everything to others.21．The happiest people should be those whoA．face up to difficulties in lifeB．hope to be young againC．enjoy life in different agesD．wish to be grown up
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4 David Silvester is the founder and owner of a recently formed gift packaging company, Gift Designs Ltd. David hasspotted an opportunity for a new type of gift packaging. This uses a new process to make waterproof cardboard andthen shapes and cuts the card in such a way to produce a container or vase for holding cut flowers. The containerscan be stored flat and in bulk and then simply squeezed to create the flowerpot into which flowers and water are thenput. The potential market for the product is huge. In the UK hospitals alone there are 200,000 bunches of flowersbought each year for patients. David’s innovative product does away with the need for hospitals to provide and storeglass vases. The paper vases are simple, safe and hygienic. He has also identified two other potential markets; firstly,the market for fresh flowers supplied by florists and secondly, the corporate gift market where clients such as cardealers present a new owner with an expensive bunch of flowers when the customer takes delivery of a new car. Thevase can be printed using a customer’s design and logo and creates an opportunity for real differentiation and impactat sales conferences and other high profile PR events.David anticipates a rapid growth in Gift Designs as its products become known and appreciated. The key question ishow quickly the company should grow and the types of funding needed to support its growth and development. Theinitial financial demands of the business have been quite modest but David has estimated that the business needs￡500K to support its development over the next two years and is uncertain as to the types of funding best suited toa new business as it looks to grow rapidly. He understands that business risk and financial risk is not the same thingand is looking for advice on how he should organise the funding of the business. He is also aware of the need to avoidreliance on friends and family for funding and to broaden the financial support for the business. Clearly the fundingrequired would also be affected by the activities David decides to carry out himself and those activities better providedby external suppliers.Required:(a) Provide David with a short report on the key issues he should take into account when developing a strategyfor funding Gift Designs’ growth and development. (10 marks)
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For this part, assume today’s date is 15 August 2005.5 (a) Donald is aged 22, single, and about to finish his university education. He has plans to start up a business sellingcomputer games, and intends to start trading on 1 April 2006, making up accounts to 31 March annually.He believes that his business will generate cash (equal to taxable profits) of ￡47,500 in the first year. Heoriginally intended to operate as a sole trader, but he has recently discovered that as an alternative, he couldoperate through a company. He has been advised that if this is the case, he can take a maximum gross salaryof ￡42,648 out of the company.Required:(i) Advise Donald on the income tax (IT), national insurance (NIC) and corporation tax (CT) liabilities hewill incur for the year ended 31 March 2007 trading under each of the two alternative businessstructures (sole trade/company). Your advice should be supported by calculations of disposable incomefor both alternatives assuming that in the company case, he draws the maximum salary stated.(7 marks)
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6 Alasdair, aged 42, is single. He is considering investing in property, as he has heard that this represents a goodinvestment. In order to raise the funds to buy the property, he wants to extract cash from his personal company, BeezerLimited, whose year end is 31 December.Beezer Limited was formed on 1 May 1998 with ￡1,000 of capital issued as 1,000 ￡1 ordinary shares, and tradeduntil 1 January 2005 when Alasdair sold the trade and related assets. The company’s only asset is cash of￡120,000. Alasdair wants to extract this cash from the company with the minimum amount of tax payable. He isconsidering either, paying himself a dividend of ￡120,000, on 31 March 2006, after which the company would haveno assets and be wound up or, leaving the cash in the company and then liquidating the company. Costs of liquidationof ￡5,000 would then be incurred.Since Beezer Limited ceased trading, Alasdair has been taken on as a partner at a marketing firm, Gallus Co. Heestimates his profit share for the year of assessment 2005/06 will be ￡30,000. He has not made any capital disposalsin the current tax year.Alasdair wishes to reinvest the cash extracted from Beezer Limited in property but is not sure whether he should investdirectly in residential or commercial property, or do so via some form. of collective investment. He is aware that Gallus Co are looking to rent a new warehouse which could be bought for ￡200,000. Alasdair thinks that he may be ableto buy the warehouse himself and lease it to his firm, but only if he can borrow the additional money to buy theproperty.Alasdair has a 25% shareholding in another company, Glaikit Limited, whose year end is 31 March. The remainingshares in this company are held by his friend, Gill. Alasdair is considering borrowing ￡15,000 from Glaikit Limitedon 1 January 2006. He does not intend to pay any interest on the loan, which is likely to be written off some timein 2007. Alasdair does not have any connection with Glaikit Limited other than his shareholding.Required:(a) Advise Alasdair whether or not a dividend payment will result in a higher after-tax cash sum than theliquidation of Beezer Limited. Assume that either the dividend would be paid on 31 March 2006 or theliquidation would take place on 31 March 2006. (9 marks)Assume that Beezer Limited has always paid corporation tax at or above the small companies rate of 19%and that the tax rates and allowances for 2004/05 apply throughout this part.
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3 Assume that today’s date is 10 May 2005.You have recently been approached by Fred Flop. Fred is the managing director and 100% shareholder of FlopLimited, a UK trading company with one wholly owned subsidiary. Both companies have a 31 March year-end.Fred informs you that he is experiencing problems in dealing with aspects of his company tax returns. The companyaccountant has been unable to keep up to date with matters, and Fred also believes that mistakes have been madein the past. Fred needs assistance and tells you the following:Year ended 31 March 2003The corporation tax return for this period was not submitted until 2 November 2004, and corporation tax of ￡123,500was paid at the same time. Profits chargeable to corporation tax were stated as ￡704,300.A formal notice (CT203) requiring the company to file a self-assessment corporation tax return (dated 1 February2004) had been received by the company on 4 February 2004.A detailed examination of the accounts and tax computation has revealed the following.– Computer equipment totalling ￡50,000 had been expensed in the accounts. No adjustment has been made inthe tax computation.– A provision of ￡10,000 was made for repairs, but there is no evidence of supporting information.– Legal and professional fees totalling ￡46,500 were allowed in full without any explanation. Fred hassubsequently produced the following analysis:Analysis of legal professional fees￡Legal fees on a failed attempt to secure a trading loan 15,000Debt collection agency fees 12,800Obtaining planning consent for building extension 15,700Accountant’s fees for preparing accounts 14,000Legal fees relating to a trade dispute 19,000– No enquiry has yet been raised by the Inland Revenue.– Flop Ltd was a large company in terms of the Companies Act definition for the year in question.– Flop Ltd had taxable profits of ￡595,000 in the previous year.Year ended 31 March 2004The corporation tax return has not yet been submitted for this year. The accounts are late and nearing completion,with only one change still to be made. A notice requiring the company to file a self-assessment corporation tax return(CT203) dated 27 July 2004 was received on 1 August 2004. No corporation tax has yet been paid.1 – The computation currently shows profits chargeable to corporation tax of ￡815,000 before accountingadjustments, and any adjustments for prior years.– A company owing Flop Ltd ￡50,000 (excluding VAT) has gone into liquidation, and it is unlikely that any of thismoney will be paid. The money has been outstanding since 3 September 2003, and the bad debt will need tobe included in the accounts.1 Fred also believes there are problems in relation to the company’s VAT administration. The VAT return for the quarterended 31 March 2005 was submitted on 5 May 2005, and VAT of ￡24,000 was paid at the same time. The previousreturn to 31 December 2004 was also submitted late. In addition, no account has been made for the VAT on the baddebt. The VAT return for 30 June 2005 may also be late. Fred estimates the VAT liability for that quarter to be ￡8,250.Required:(a) (i) Calculate the revised corporation tax (CT) payable for the accounting periods ending 31 March 2003and 2004 respectively. Your answer should include an explanation of the adjustments made as a resultof the information which has now come to light. (7 marks)(ii) State, giving reasons, the due payment date of the corporation tax (CT) and the filing date of thecorporation tax return for each period, and identify any interest and penalties which may have arisen todate. (8 marks)
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6 Assume today’s date is 16 April 2005.Henry, aged 48, is the managing director of Happy Home Ltd, an unquoted UK company specialising in interiordesign. He is wealthy in his own right and is married to Helen, who is 45 years old. They have two children – Stephen,who is 19, and Sally who is 17.As part of his salary, Henry was given 3,000 shares in Happy Home Ltd with an option to acquire a further 10,000shares. The options were granted on 15 July 2003, shortly after the company started trading, and were not part ofan approved share option scheme. The free shares were given to Henry on the same day.The exercise price of the share options was set at the then market value of ￡1·00 per share. The options are notcapable of being exercised after 10 years from the date of grant. The company has been successful, and the currentvalue of the shares is now ￡14·00 per share. Another shareholder has offered to buy the shares at their market value,so Henry exercised his share options on 14 April 2005 and will sell the shares next week, on 20 April 2005.With the company growing in size, Henry wishes to recruit high quality staff, but the company lacks the funds to paythem in cash. Henry believes that giving new employees the chance to buy shares in the company would help recruitstaff, as they could share in the growth in value of Happy Home Ltd. Henry has heard that there is a particular sharescheme that is suitable for small, fast growing companies. He would like to obtain further information on how sucha scheme would work.Henry has accumulated substantial assets over the years. The family house is owned jointly with Helen, and is worth￡650,000. Henry has a ￡250,000 mortgage on the house. In addition, Henry has liquid assets worth ￡340,000and Helen has shares in quoted companies currently worth ￡125,000. Henry has no forms of insurance, and believeshe should make sure that his wealth and family are protected. He is keen to find out what options he should beconsidering.Required:(a) (i) State how the gift of the 3,000 shares in Happy Home Ltd was taxed. (1 mark)
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2 Benny Korere has been employed as the sales director of Golden Tan plc since 1994. He earns an annual salary of￡32,000 and is provided with a petrol-driven company car which has a CO2 emission rate of 187g/km and had alist price when new of ￡22,360. In August 2003, when he was first provided with the car, Benny paid the company￡6,100 towards the capital cost of the car. Golden Tan plc does not pay for any of Benny’s private petrol and he isalso required to pay his employer ￡18 per month as a condition of being able to use the car for private purposes.On 1 December 2006 Golden Tan plc notified Benny that he would be made redundant on 28 February 2007. Onthat day the company will pay him his final month’s salary together with a payment of ￡8,000 in lieu of the threeremaining months of his six-month notice period in accordance with his employment contract. In addition thecompany will pay him ￡17,500 in return for agreeing not to work for any of its competitors for the six-month periodending 31 August 2007.On receiving notification of his redundancy, Benny immediately contacted Joe Egmont, the managing director ofSummer Glow plc, who offered him a senior management position leading the company’s expansion into EasternEurope. Summer Glow plc is one of Golden Tan plc’s competitors and one of the most innovative companies in theindustry, although not all of its strategies have been successful.Benny has agreed to join Summer Glow plc on 1 September 2007 for an annual salary of ￡39,000. On the day hejoins the company, Summer Glow plc will grant him an option to purchase 10,000 ordinary shares in the companyfor ￡2·20 per share under an unapproved share option scheme. Benny can exercise the option once he has beenemployed for six months but must hold the shares for at least a year before he sells them.The new job will require Benny to spend a considerable amount of time in London. Summer Glow plc has offeredBenny the exclusive use of a flat that the company purchased on 1 June 2003 for ￡165,000; the flat is currentlyrented out. The flat will be made available from 1 September 2007. The company will pay all of the utility billsrelating to the flat as well as furnishing and maintaining it. Summer Glow plc has also suggested that if Benny wouldrather live in a more central part of the city, the company could sell the existing flat and buy a more centrally locatedone, of the same value, with the proceeds.On 15 March 2007 Benny intends to sell 5,800 shares in Mahana plc, a quoted company, for ￡24,608. Histransactions in the company’s shares have been as follows:￡June 1988 Purchased 8,400 shares 6,744February 1996 Sale of rights nil paid 610January 2005 Purchased 1,300 shares 2,281The sale of rights, nil paid, was not treated as a part disposal of Benny’s holding in Mahana plc.Benny’s shareholding in Mahana plc represents less than 1% of the company’s issued ordinary share capital. He willnot make any other capital disposals in 2006/07.In addition to his employment income, Benny receives rental income of ￡4,000 (net of deductible expenses) eachyear. He normally submits his tax return in August but he has not yet prepared his return for 2005/06. He expectsto be very busy in December and January and is planning to prepare his tax return in late February 2007.Required:(a) Calculate Benny’s employment income for 2006/07. (4 marks)
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(b) Peter, one of Linden Limited’s non-executive directors, having lived and worked in the UK for most of his adultlife, sold his home near London on 22 March 2006 and, together with his wife (a French citizen), moved to livein a villa which she owns in the south of France. Peter is now demanding that the tax deducted from his director’sfees, for the board meetings held on 18 April and 16 May 2006, be refunded, on the grounds that, as he is nolonger resident in the UK, he is no longer liable to UK income tax. All of the company’s board meetings are heldat its offices in Cambridge.Despite Peter’s assurance that none of the other companies of which he is a director has disputed his change oftax status, Damian is uncertain whether he should make the refunds requested. However, as Peter is a friend ofthe company’s founder, Linden Limited’s managing director is urging him to do so, stating that if the tax doeshave to be paid, then Linden Limited could always bear the cost.Required:Advise Damian whether Peter is correct in his assertion regarding his tax position and in the case that thereis a UK tax liability the implications of the managing director’s suggestion. You are not required to considernational insurance (NIC) issues. (4 marks)
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4 (a) For this part, assume today’s date is 1 March 2006.Bill and Ben each own 50% of the ordinary share capital in Flower Limited, an unquoted UK trading companythat makes electronic toys. Flower Limited was incorporated on 1 August 2005 with 1,000 ￡1 ordinary shares,and commenced trading on the same day. The business has been successful, and the company has accumulateda large cash balance of ￡180,000, which is to be used to purchase a new factory. However, Bill and Ben havereceived an offer from a rival company, which they are considering. The offer provides Bill and Ben with twoalternative methods of payment for the purchase of their shares:(i) ￡480,000 for the company, inclusive of the ￡180,000 cash balance.(ii) ￡300,000 for the company assuming the cash available for the factory purchase is extracted prior to sale.Bill and Ben each currently receive a gross salary of ￡3,750 per month from Flower Limited. Part of the offerterms is that Bill and Ben would be retained as employees of the company on the same salary.Neither Bill nor Ben has used any of their capital gains tax annual exemption for the tax year 2005/06.Required:(i) Calculate which of the following means of extracting the ￡180,000 from Flower Limited on 31 March2006 will result in the highest after tax cash amount for Bill and Ben:(1) payment of a dividend, or(2) payment of a salary bonus.You are not required to consider the corporation tax (CT) implications for Flower Limited in youranswer. (5 marks)
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2 Clifford and Amanda, currently aged 54 and 45 respectively, were married on 1 February 1998. Clifford is a higherrate taxpayer who has realised taxable capital gains in 2007/08 in excess of his capital gains tax annual exemption.Clifford moved into Amanda’s house in London on the day they were married. Clifford’s own house in Oxford, wherehe had lived since acquiring it for ￡129,400 on 1 August 1996, has been empty since that date although he andAmanda have used it when visiting friends. Clifford has been offered ￡284,950 for the Oxford house and has decidedthat it is time to sell it. The house has a large garden such that Clifford is also considering an offer for the house anda part only of the garden. He would then sell the remainder of the garden at a later date as a building plot. His totalsales proceeds will be higher if he sells the property in this way.Amanda received the following income from quoted investments in 2006/07:￡Dividends in respect of quoted trading company shares 1,395Dividends paid by a Real Estate Investment Trust out of tax exempt property income 485On 1 May 2006, Amanda was granted a 22 year lease of a commercial investment property. She paid the landlorda premium of ￡6,900 and also pays rent of ￡2,100 per month. On 1 June 2006 Amanda granted a nine yearsub-lease of the property. She received a premium of ￡14,700 and receives rent of ￡2,100 per month.On 1 September 2006 Amanda gave quoted shares with a value of ￡2,200 to a registered charity. She paid broker’sfees of ￡115 in respect of the gift.Amanda began working for Shearer plc, a quoted company, on 1 June 2006 having had a two year break from hercareer. She earns an annual salary of ￡38,600 and was paid a bonus of ￡5,750 in August 2006 for agreeing tocome and work for the company. On 1 August 2006 Amanda was provided with a fully expensed company car,including the provision of private petrol, which had a list price when new of ￡23,400 and a CO2 emissions rate of187 grams per kilometre. Amanda is required to pay Shearer plc ￡22 per month in respect of the private use of thecar. In June and July 2006 Amanda used her own car whilst on company business. She drove 720 business milesduring this two month period and was paid 34 pence per mile. Amanda had PAYE of ￡6,785 deducted from her grosssalary in the tax year 2006/07.After working for Shearer plc for a full year, Amanda becomes entitled to the following additional benefits:– The opportunity to purchase a large number of shares in Shearer plc on 1 July 2007 for ￡3·30 per share. It isanticipated that the share price on that day will be at least ￡7·50 per share. The company will make an interestfreeloan to Amanda equal to the cost of the shares to be repaid in two years.– Exclusive free use of the company sailing boat for one week in August 2007. The sailing boat was purchased byShearer plc in January 2005 for use by its senior employees and costs the company ￡1,400 a week in respectof its crew and other running expenses.Required:(a) (i) Calculate Clifford’s capital gains tax liability for the tax year 2007/08 on the assumption that the Oxfordhouse together with its entire garden is sold on 31 July 2007 for ￡284,950. Comment on the relevanceto your calculations of the size of the garden; (5 marks)
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5 Crusoe has contacted you following the death of his father, Noland. Crusoe has inherited the whole of his father’sestate and is seeking advice on his father’s capital gains tax position and the payment of inheritance tax following hisdeath.The following information has been extracted from client files and from telephone conversations with Crusoe.Noland – personal information:– Divorcee whose only other relatives are his sister, Avril, and two grandchildren.– Died suddenly on 1 October 2007 without having made a will.– Under the laws of intestacy, the whole of his estate passes to Crusoe.Noland – income tax and capital gains tax:– Has been a basic rate taxpayer since the tax year 2000/01.– Sales of quoted shares resulted in:– Chargeable gains of ￡7,100 and allowable losses of ￡17,800 in the tax year 2007/08.– Chargeable gains of approximately ￡14,000 each tax year from 2000/01 to 2006/07.– None of the shares were held for long enough to qualify for taper relief.Noland – gifts made during lifetime:– On 1 December 1999 Noland gave his house to Crusoe.– Crusoe has allowed Noland to continue living in the house and has charged him rent of ￡120 per monthsince 1 December 1999. The market rent for the house would be ￡740 per month.– The house was worth ￡240,000 at the time of the gift and ￡310,000 on 1 October 2007.– On 1 November 2004 Noland transferred quoted shares worth ￡232,000 to a discretionary trust for the benefitof his grandchildren.Noland – probate values of assets held at death: ￡– Portfolio of quoted shares 370,000Shares in Kurb Ltd 38,400Chattels and cash 22,300Domestic liabilities including income tax payable (1,900)– It should be assumed that these values will not change for the foreseeable future.Kurb Ltd:– Unquoted trading company– Noland purchased the shares on 1 December 2005.Crusoe:– Long-standing personal tax client of your firm.– Married with two young children.– Successful investment banker with very high net worth.– Intends to gift the portfolio of quoted shares inherited from Noland to his aunt, Avril, who has very little personalwealth.Required:(a) Prepare explanatory notes together with relevant supporting calculations in order to quantify the tax reliefpotentially available in respect of Noland’s capital losses realised in 2007/08. (4 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) Calculate the amount of input tax that will be recovered by Vostok Ltd in respect of the new premises in theyear ending 31 March 2009 and explain, using illustrative calculations, how any additional recoverable inputtax will be calculated in future years. (5 marks)
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3 The Stiletto Partnership consisted of three partners, Clint, Ben and Amy, who shared the profits of the businessequally. On 28 February 2007 the partners sold the business to Razor Ltd, in exchange for shares in Razor Ltd, witheach former partner owning one third of the new company.The recent, tax adjusted, trading profits of the Stiletto Partnership have been as follows:￡Year ended 30 June 2006 92,1241 July 2006 to 28 February 2007 81,795Clint, who was 65 on 5 October 2006, retired when the business was sold to Razor Ltd. He is now suggesting thatif the sale of the partnership, and his retirement, had been delayed until 30 April 2007, his total tax liability wouldhave been reduced. Clint’s only other income is gross pension income of ￡6,100 per year, which he began receivingin the tax year 2005/06. Clint did not receive any salary or dividends from Razor Ltd. It is estimated that thepartnership’s tax adjusted trading profits for the period from 1 March 2007 to 30 April 2007 would have been￡20,760. Clint has overlap profits of ￡14,250 brought forward from when the partnership began trading.Razor Ltd manufactures industrial cutting tools. On 1 July 2007, Razor Ltd will subscribe for the whole of the ordinaryshare capital of Cutlass Inc, a company newly incorporated in the country of Sharpenia. It is intended that CutlassInc will purchase partly finished tools from Razor Ltd and customise them in Sharpenia. It is anticipated that CutlassInc’s annual profits chargeable to corporation tax will be approximately ￡120,000.Ben and Amy will be the directors of Cutlass Inc, although Ben will not be involved in the company’s business on aday-to-day basis. Amy intends to spend one or two weeks each month in the country of Sharpenia looking after thecompany’s affairs. The remainder of her time will be spent in the UK. Amy has employment contracts with both RazorLtd and Cutlass Inc and her duties for Cutlass Inc will be carried out wholly in Sharpenia. Cutlass Inc will pay forAmy’s flights to and from Sharpenia and for her husband and baby to visit her there twice a year. Amy is currentlyUK resident and ordinarily resident.The system of income tax and corporation tax in the country of Sharpenia is broadly similar to that in the UK althoughthe rate of corporation tax is 38% regardless of the level of profits. There is a double tax treaty between the UK andSharpenia based on the OECD model treaty. The clause in the treaty dealing with company residency states that acompany resident in both countries under domestic law will be regarded under the treaty as being resident only in thecountry where it is effectively managed and controlled. Sharpenia is not a member of the European Union.Required:(a) (i) Calculate Clint’s taxable trading profits for the tax years 2006/07 and 2007/08 for both of thealternative retirement dates (28 February 2007 and 30 April 2007). (3 marks)
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Dear Mr. Brown,Thank you for your letter of 6 September regarding Mr. John Green who has been employed by this company for the past 10 years.Mr. Green served his apprenticeship (学徒) with Vickers Tools Ltd. in Manchester, followed by a three-year course of engineering for Production Engineers. He is technically well—qualified and for the past five years has been our Assistant Works Manager responsible for production and related business in our Sheffield factory. In all his job duties he has shown himself to be hard-working, responsible and in every way a very dependable employee.I can strongly recommend Mr. Green as I feel sure that if he were to be chosen to manage your factory in Nairobi he would bring to his work a true atmosphere of teamwork, which would be found necessary and helpful by all who would work with him.Sincerely yours，Tom Smith1. How long has Mr. Green been employed by the writer's company?For ().2. What kind of course did Mr. Green take?A three-year course in engineering for ().3. What job position has Mr. Green held in the past five years?4.What does the writer think of Mr. Green as an employee?He is hard-working, () and dependable.5.What is the purpose of this letter?To () Mr. Green to manage a factory in Nairobi.
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How often one hears children wishing they were grown up，and old people wishing they were young again. Each age has its pleasures and its pains，and the happiest person is the one who enjoys what each age gives him without wasting his time in useless regrets.Childhood is a time when there are few responsibilities. If a child has good parents，he is well fed，looked after and loved. It is unlikely that he will ever again in his life be given so much without having to do anything in return. In addition，life is always presenting new things to the child-things that have lost their，interest for older people because they are too well known. A child finds pleasure in playing in the rain，or in the snow. His first，visit to the seaside is a marvelous adventure. But a child has his pains：he is not so free to do as he wishes as he thinks older people are；he is continually being told what to do and what not to do. Therefore，a child is not happy as he wishes to be.When the young man starts to earn his own living，he becomes free from the discipline of school and parents；but at the same time he is forced to accept responsibilities. With no one to pay for his food，his clothes，or his room，he has to work if he wants to live comfortably. If he spends most of his time playing about in the way that he used to as a child，he will go hungry. And if he breaks the laws of society as he used to break the laws of his parents，he may get himself into trouble. If，however，he works hard，goes by the law and has good health，he may feel satisfied in seeing himself make steady progress in his job and in building up for himself his own position in society.Old age has always been thought of as the worst age to be；but it is not necessary for the old to be unhappy. With old age comes wisdom and the ability to help others with advice wisely given. The old can have the joy of seeing their children making progress in life；they can watch their grandchildren growing up around them；and，perhaps best of all，they can，if their life has been a useful one，feel the happiness of having come through the battle of life safely and of having reached a time when they can lie back and rest，leaving everything to others.The happiest people should be those who______.A．face up to difficulties in lifeB．hope to be young againC．enjoy life in different agesD．wish to be grown up
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根据以下内容，回答202-206题。
The Daily Inquirer
October 8
Book Review of Anne Narazaki's
New Century, New Business
Reviewed by John Gilliam
Anne Narazaki's recent book, New Century, New Business, seeks to examine the new tech-nologies that are critical for global business and how they affect today's corporate transactions. Ms.Narazaki argues that while economic transactions of one kind or another have taken place for thou-sands of years, the impact of changing technology on business has become obvious only recently. In fact, as new technologies have grown more prevalent, Ms. Narazaki observes, international busi-nesses have increased in size and number. At the same time, the time required to conduct each business transaction has decreased.
Mr. Narazaki illustrates her observations with detailed examples of recent business transac-tions. Citing the merger of Poynter Technologies and Carce Company, which created the largest fi-nancial services company in the world, Ms. Narazaki explains the effect technology has on the val-uation of a company, on communication between the managements of different companies, and on stock and funds trading.
Those of us who take an interest in the interaction between business and technology will find Ms. Narazaki's ideas persuasive. The view that business cannot survive without keep~ing up with new technology has become today's corporate reality.
In the article, the word "critical" in paragraph 1 is closest in meaning to （ ）。A.growing
B.sensitive
C.disapproving
D.important
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共用题干
A Success StoryAt 19,Ben Way is already a millionaire,and one of a growing number of teenagers who have ______(51)their fortune through the Internet.______(52)makes Ben's story all the more remarkable is that he is dyslexic,and was______(53)by teachers at his junior school that he would never be able to read or write______(54).“I wanted to prove them______(55)”, says Ben,creator and director of Waysearch,a net search engine which can be used ______(56)find goods in online shopping malls.When he was eight,his local authorities provided him with a PC to help with school work.Although he was______(57)to read the manuals,he had a natural ability with the computer, and______(58)by his father,he soon began______(59)people￡10 an hour for hisknowledge and skills.At the age of 15 he______(60)up his own computer consultancy, Quad Computer,which he ran from his bedroom,and two years later he left school to ______(61)all his time to business.“By this time the company had grown and I needed to take on a______(62)of employees to help me”,says Ben.“That enabled me to start doing business with______(63)companies.”It was his ability to consistently______(64)difficult challenges that led him to win the Young Entrepreneur of the Year award in the same year that he formed Waysearch,and he has re-cently signed a deal______(65)￡25 million with a private investment company,which will finance his search engine.61._________A: payB: spendC: devoteD: invest
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共用题干
A Success StoryAt 19,Ben Way is already a millionaire,and one of a growing number of teenagers who have ______(51)their fortune through the Internet.______(52)makes Ben's story all the more remarkable is that he is dyslexic,and was______(53)by teachers at his junior school that he would never be able to read or write______(54).“I wanted to prove them______(55)”, says Ben,creator and director of Waysearch,a net search engine which can be used ______(56)find goods in online shopping malls.When he was eight,his local authorities provided him with a PC to help with school work.Although he was______(57)to read the manuals,he had a natural ability with the computer, and______(58)by his father,he soon began______(59)people￡10 an hour for hisknowledge and skills.At the age of 15 he______(60)up his own computer consultancy, Quad Computer,which he ran from his bedroom,and two years later he left school to ______(61)all his time to business.“By this time the company had grown and I needed to take on a______(62)of employees to help me”,says Ben.“That enabled me to start doing business with______(63)companies.”It was his ability to consistently______(64)difficult challenges that led him to win the Young Entrepreneur of the Year award in the same year that he formed Waysearch,and he has re-cently signed a deal______(65)￡25 million with a private investment company,which will finance his search engine.64._________A: overcomeB: overlookC: overtakeD: overdo
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Companycom is about to purchase a POWER5 Enterprise server which requires two Ethernet ports and two disks for each of the four LPARs. It has been configured and validated using the IBM eConfig tool. Which of the following is very important to verify in addition to the eConfig validation?（）A、Total number of SCSI adaptersB、Total number of Ethernet adaptersC、Total number of Ethernet adapters and number of SCSI paths per LPARD、Total number of SCSI paths available and total number of SCSI adapters
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A global container shipping company has a new application that they are going to deploy on a p5-570 at their corporate data center. The Chief Information Officer indicates that， if the application is down for more than 36 hours， the cost of downtime is very high. For the initial 36 hours of downtime， the company has a manual process they can execute without significant additional cost. Which of the following products best mitigates the major business risk to the company？（）A、IBM Business Continuity ServicesB、HACMP and a second p5-570 for the data centerC、ServiceSuite Supportline with Account AdvocateD、ServiceSuite 9x5 next day Hardware Maintenance
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问答题Passage 2 A land free from destruction, wealth, natural resources, and labor supply--all these were important 1 in helping England to become the center for the Industrial Revolution. 2 they were not enough. Something 3 was needed to start the industrial process. That "something special", was men-- creative individuals who could invent machines, find new sources of power, and 4 business organizations to reshape the society. The men who created the machines of the Industrial Revolution 5 from many backgrounds and many occupations. Many of them were 6 inventors than scientists. A man who is a pure scientist is primarily interested in doing his research accurately. He is not necessarily working 7 that his findings can be used. An inventor or one interested in applied science is usually trying to make something 8 has a concrete use. He tries to solve a problem by following the theories of science or by experimenting 9 trial and error. Regardless 10 his method, he is working to obtain a specific result: the construction of a harvesting machine, the burning of a light bulb, or one of many other objectives. Most of the people who developed the machines of the Industrial Revolution were 11 . A 12 were both scientists and inventors. Even those who had little or no training 13 science might have made their inventions, 14 a groundwork had been laid by scientists years 15 .
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问答题Practice 5 ● Your company has decided to invest some of this year’s exceptionally high profits in one of the following areas: ● New company buses ● Culture comparative Courses ● Special bonus payments. ● You have been asked to write a report recommending how the profits should be invested and what benefits they would bring respectively. ● Write 200-250 words on your Answer Sheet.
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问答题Practice 1 Some people call him “Guidone”—big Guido. Large in both physical stature and reputation, Guido Rossi, who took over as Telecom Italia's chairman on September 15th following the surprise resignation of Marco Tronchetti Provera, has stood out from the Italian business crowd for more than three decades. Mr. Rossi, who attended Harvard law school in the 1950s and wrote a book on American bankruptcy law, made his name as a corporate lawyer keen on market rules and their enforcement. He has since worked in both private and public sectors, including stints in the Italian Senate and as one of the European Commission's group of company-law experts. As well as running a busy legal practice, he also has a reputation as a corporate troubleshooter and all-round Mr Fix-It, and is often called upon to clean up organisations in crisis. His role at Telecom Italia marks a return to the company he headed for ten months in 1997, during its politically tricky and legally complex privatisation. Before that, Mr Rossi had been sent in to sort out Ferruzzi-Montedison, an agri-business and chemicals group, which had collapsed after magistrates uncovered tangentopoli (“bribesville”).
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问答题Practice 3 ● Your manager is considering whether to purchase or to rent a new company premise. He has asked you to write a report concerning this. ● Write a report for your manager, including the following information: ● what you know about the premise, ● why it is good for you to take the relevant action, ● how your company would benefit from it. ● Write 200-250 words.
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单选题Federal tax evasion is a serious crime that places an unfair tax burden on those members of society who pay their fair share. To reduce the incidence of tax evasion, the government needs to prosecute a few high• profile individuals whose cases will receive substantial media attention.The argument above relies on which of the following assumptions?A
The tax system is so complicated that even people who try to comply with it may inadvertently not pay some of their taxes.B
The average citizen will be less likely to evade taxes after he or she sees a high-profile individual prosecuted for tax evasion.C
Tax revenues collected from high-profile tax evaders will help to alleviate the unfair tax burden on honest citizens.D
Although it is difficult to secure a conviction on a charge of tax evasion, if the government focuses its efforts on a small number of high-profile individuals, the odds of obtaining a conviction will increase.E
While there is no universal measure for determining whether a taxation system is “fair” or “unfair,” the current system was constructed by Congress to represent the societal priorities and values of the American people.
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