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(b) Prepare a reasoned explanation of how any capital gains tax arising in the UK on the sale of the paintings
can be minimised. (2 marks)
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更多 “ (b) Prepare a reasoned explanation of how any capital gains tax arising in the UK on the sale of the paintingscan be minimised. (2 marks) ” 相关考题
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(b) (i) Discuss the main factors that should be taken into account when determining how to treat gains andlosses arising on tangible non-current assets in a single statement of financial performance. (8 marks)
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(iii) A statement on the importance of confidentiality in the financing of the early stage working capital needsand an explanation of how this conflicts with the duty of transparency in matters of corporategovernance. (6 marks)Professional marks for layout, logical flow and persuasiveness of the statement. (4 marks)
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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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(c) Assuming that Joanne registers for value added tax (VAT) with effect from 1 April 2006:(i) Calculate her income tax (IT) and capital gains tax (CGT) payable for the year of assessment 2005/06.You are not required to calculate any national insurance liabilities in this sub-part. (6 marks)
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(ii) State, giving reasons, the tax reliefs in relation to inheritance tax (IHT) and capital gains tax (CGT) whichwould be available to Alasdair if he acquires the warehouse and leases it to Gallus Co, rather than toan unconnected tenant. (4 marks)
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(c) (i) Explain the capital gains tax (CGT) implications of a takeover where the consideration is in the form. ofshares (a ‘paper for paper’ transaction) stating any conditions that need to be satisfied. (4 marks)
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(b) Assuming that the income from the sale of the books is not treated as trading income, calculate Bob’s taxableincome and gains for all relevant tax years, using any loss reliefs in the most tax-efficient manner. Youranswer should include an explanation of the loss reliefs available and your reasons for using (or not using)them. (12 marks)Assume that the rates and allowances for 2004/05 apply throughout this part of the question.
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(c) Advise Alan on the proposed disposal of the shares in Mobile Ltd. Your answer should include calculationsof the potential capital gain, and explain any options available to Alan to reduce this tax liability. (7 marks)
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(ii) Explain the income tax (IT), national insurance (NIC) and capital gains tax (CGT) implications arising onthe grant to and exercise by an employee of an option to buy shares in an unapproved share optionscheme and on the subsequent sale of these shares. State clearly how these would apply in Henry’scase. (8 marks)
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3 On 1 January 2007 Dovedale Ltd, a company with no subsidiaries, intends to purchase 65% of the ordinary sharecapital of Hira Ltd from Belgrove Ltd. Belgrove Ltd currently owns 100% of the share capital of Hira Ltd and has noother subsidiaries. All three companies have their head offices in the UK and are UK resident.Hira Ltd had trading losses brought forward, as at 1 April 2006, of ￡18,600 and no income or gains against whichto offset losses in the year ended 31 March 2006. In the year ending 31 March 2007 the company expects to makefurther tax adjusted trading losses of ￡55,000 before deduction of capital allowances, and to have no other incomeor gains. The tax written down value of Hira Ltd’s plant and machinery as at 31 March 2006 was ￡96,000 andthere will be no fixed asset additions or disposals in the year ending 31 March 2007. In the year ending 31 March2008 a small tax adjusted trading loss is anticipated. Hira Ltd will surrender the maximum possible trading lossesto Belgrove Ltd and Dovedale Ltd.The tax adjusted trading profit of Dovedale Ltd for the year ending 31 March 2007 is expected to be ￡875,000 andto continue at this level in the future. The profits chargeable to corporation tax of Belgrove Ltd are expected to be￡38,000 for the year ending 31 March 2007 and to increase in the future.On 1 February 2007 Dovedale Ltd will sell a small office building to Hira Ltd for its market value of ￡234,000.Dovedale Ltd purchased the building in March 2005 for ￡210,000. In October 2004 Dovedale Ltd sold a factoryfor ￡277,450 making a capital gain of ￡84,217. A claim was made to roll over the gain on the sale of the factoryagainst the acquisition cost of the office building.On 1 April 2007 Dovedale Ltd intends to acquire the whole of the ordinary share capital of Atapo Inc, an unquotedcompany resident in the country of Morovia. Atapo Inc sells components to Dovedale Ltd as well as to othercompanies in Morovia and around the world.It is estimated that Atapo Inc will make a profit before tax of ￡160,000 in the year ending 31 March 2008 and willpay a dividend to Dovedale Ltd of ￡105,000. It can be assumed that Atapo Inc’s taxable profits are equal to its profitbefore tax. The rate of corporation tax in Morovia is 9%. There is a withholding tax of 3% on dividends paid tonon-Morovian resident shareholders. There is no double tax agreement between the UK and Morovia.Required:(a) Advise Belgrove Ltd of any capital gains that may arise as a result of the sale of the shares in Hira Ltd. Youare not required to calculate any capital gains in this part of the question. (4 marks)
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(c) (i) Compute Gloria’s capital gains tax liability for 2006/07 ignoring any claims or elections available toreduce the liability. (3 marks)
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(d) Explain how Gloria would be taxed in the UK on the dividends paid by Bubble Inc and the capital gains taxand inheritance tax implications of a future disposal of the shares. Clearly state, giving reasons, whether ornot the payment made to Eric is allowable for capital gains tax purposes. (9 marks)You should assume that the rates and allowances for the tax year 2005/06 apply throughout this question.
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(ii) Assuming the relief in (i) is available, advise Sharon on the maximum amount of cash she could receiveon incorporation, without triggering a capital gains tax (CGT) liability. (3 marks)
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(c) Explain the capital gains tax (CGT) and income tax (IT) issues Paul and Sharon should consider in decidingwhich form. of trust to set up for Gisella and Gavin. You are not required to consider inheritance tax (IHT) orstamp duty land tax (SDLT) issues. (10 marks)You should assume that the tax rates and allowances for the tax year 2005/06 apply throughout this question.
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(iii) State the value added tax (VAT) and stamp duty (SD) issues arising as a result of inserting Bold plc asa holding company and identify any planning actions that can be taken to defer or minimise these taxcosts. (4 marks)You should assume that the corporation tax rates for the financial year 2005 and the income tax ratesand allowances for the tax year 2005/06 apply throughout this question.
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(ii) Advise Andrew of the tax implications arising from the disposal of the 7% Government Stock, clearlyidentifying the tax year in which any liability will arise and how it will be paid. (3 marks)
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(b) (i) Advise Andrew of the income tax (IT) and capital gains tax (CGT) reliefs available on his investment inthe ordinary share capital of Scalar Limited, together with any conditions which need to be satisfied.Your answer should clearly identify any steps that should be taken by Andrew and the other investorsto obtain the maximum relief. (13 marks)
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(b) Calculate Alvaro Pelorus’s capital gains tax liability for the tax year 2006/07 on the assumption that allavailable reliefs are claimed. (8 marks)
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(ii) Advise Clifford of the capital gains tax implications of the alternative of selling the Oxford house andgarden by means of two separate disposals as proposed. Calculations are not required for this part ofthe question. (3 marks)
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(ii) Analyse the effect of delaying the sale of the business of the Stiletto Partnership to Razor Ltd until30 April 2007 on Clint’s income tax and national insurance position.You are not required to prepare detailed calculations of his income tax or national insurance liabilities.(4 marks)
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(b) (i) Explain, by reference to Coral’s residence, ordinary residence and domicile position, how the rentalincome arising in respect of the property in the country of Kalania will be taxed in the UK in the tax year2007/08. State the strategy that Coral should adopt in order to minimise the total income tax sufferedon the rental income. (7 marks)
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(ii) Explain how the inclusion of rental income in Coral’s UK income tax computation could affect theincome tax due on her dividend income. (2 marks)You are not required to prepare calculations for part (b) of this question.Note: you should assume that the tax rates and allowances for the tax year 2006/07 and for the financial year to31 March 2007 will continue to apply for the foreseeable future.
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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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(c) (i) Explain how Messier Ltd can assist Galileo with the cost of relocating to the UK and/or provide him withinterest-free loan finance for this purpose without increasing his UK income tax liability; (3 marks)
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(ii) State, with reasons, whether Messier Ltd can provide Galileo with accommodation in the UK withoutgiving rise to a UK income tax liability. (2 marks)
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(c) (i) Calculate Benny’s capital gains tax liability for 2006/07. (6 marks)
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