(b) (i) Advise Benny of the income tax implications of the grant and exercise of the share options in SummerGlow plc on the assumption that the share price on 1 September 2007 and on the day he exercises theoptions is ￡3·35 per share. Explain why the share option scheme is not free from risk by reference tothe rules of the scheme and the circumstances surrounding the company. (4 marks)

考题 (c) Calculate the theoretical ex rights price per share and the net funds to be raised by the rights issue, anddetermine and discuss the likely effect of the proposed expansion on:(i) the current share price of Merton plc;(ii) the gearing of the company.Assume that the price–earnings ratio of Merton plc remains unchanged at 12 times. (11 marks)

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考题 (d) Calculate the ex dividend share price predicted by the dividend growth model and discuss the company’sview that share price growth of at least 8% per year would result from expanding into the retail cameramarket. Assume a cost of equity capital of 11% per year. (6 marks)

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考题 (c) (i) State the date by which Thai Curry Ltd’s self-assessment corporation tax return for the year ended30 September 2005 should be submitted, and advise the company of the penalties that will be due ifthe return is not submitted until 31 May 2007. (3 marks)(ii) State the date by which Thai Curry Ltd’s corporation tax liability for the year ended 30 September 2005should be paid, and advise the company of the interest that will be due if the liability is not paid until31 May 2007. (3 marks)

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考题 Additionally the directors wish to know how the provision for deferred taxation would be calculated in the followingsituations under IAS12 ‘Income Taxes’:(i) On 1 November 2003, the company had granted ten million share options worth $40 million subject to a twoyear vesting period. Local tax law allows a tax deduction at the exercise date of the intrinsic value of the options.The intrinsic value of the ten million share options at 31 October 2004 was $16 million and at 31 October 2005was $46 million. The increase in the share price in the year to 31 October 2005 could not be foreseen at31 October 2004. The options were exercised at 31 October 2005. The directors are unsure how to accountfor deferred taxation on this transaction for the years ended 31 October 2004 and 31 October 2005.(ii) Panel is leasing plant under a finance lease over a five year period. The asset was recorded at the present valueof the minimum lease payments of $12 million at the inception of the lease which was 1 November 2004. Theasset is depreciated on a straight line basis over the five years and has no residual value. The annual leasepayments are $3 million payable in arrears on 31 October and the effective interest rate is 8% per annum. Thedirectors have not leased an asset under a finance lease before and are unsure as to its treatment for deferredtaxation. The company can claim a tax deduction for the annual rental payment as the finance lease does notqualify for tax relief.(iii) A wholly owned overseas subsidiary, Pins, a limited liability company, sold goods costing $7 million to Panel on1 September 2005, and these goods had not been sold by Panel before the year end. Panel had paid $9 millionfor these goods. The directors do not understand how this transaction should be dealt with in the financialstatements of the subsidiary and the group for taxation purposes. Pins pays tax locally at 30%.(iv) Nails, a limited liability company, is a wholly owned subsidiary of Panel, and is a cash generating unit in its ownright. The value of the property, plant and equipment of Nails at 31 October 2005 was $6 million and purchasedgoodwill was $1 million before any impairment loss. The company had no other assets or liabilities. Animpairment loss of $1·8 million had occurred at 31 October 2005. The tax base of the property, plant andequipment of Nails was $4 million as at 31 October 2005. The directors wish to know how the impairment losswill affect the deferred tax provision for the year. Impairment losses are not an allowable expense for taxationpurposes.Assume a tax rate of 30%.Required:(b) Discuss, with suitable computations, how the situations (i) to (iv) above will impact on the accounting fordeferred tax under IAS12 ‘Income Taxes’ in the group financial statements of Panel. (16 marks)(The situations in (i) to (iv) above carry equal marks)

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考题 (c) the deferred tax implications (with suitable calculations) for the company which arise from the recognitionof a remuneration expense for the directors’ share options. (7 marks)

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考题 3 (a) Leigh, a public limited company, purchased the whole of the share capital of Hash, a limited company, on 1 June2006. The whole of the share capital of Hash was formerly owned by the five directors of Hash and under theterms of the purchase agreement, the five directors were to receive a total of three million ordinary shares of $1of Leigh on 1 June 2006 (market value $6 million) and a further 5,000 shares per director on 31 May 2007,if they were still employed by Leigh on that date. All of the directors were still employed by Leigh at 31 May2007.Leigh granted and issued fully paid shares to its own employees on 31 May 2007. Normally share options issuedto employees would vest over a three year period, but these shares were given as a bonus because of thecompany’s exceptional performance over the period. The shares in Leigh had a market value of $3 million(one million ordinary shares of $1 at $3 per share) on 31 May 2007 and an average fair value of$2·5 million (one million ordinary shares of $1 at $2·50 per share) for the year ended 31 May 2007. It isexpected that Leigh’s share price will rise to $6 per share over the next three years. (10 marks)Required:Discuss with suitable computations how the above share based transactions should be accounted for in thefinancial statements of Leigh for the year ended 31 May 2007.

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考题 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)

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考题 (ii) Assuming that Donald operates through a company, advise Donald on the corporation tax (CT) thatwould be payable for the year ended 31 March 2007 if he pays himself a gross salary of ￡31,000, plusa net dividend of ￡10,000, instead of a gross salary of ￡42,648. (4 marks)

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考题 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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考题 (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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考题 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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考题 (ii) Advise Benny of the amount of tax he could save by delaying the sale of the shares by 30 days. For thepurposes of this part, you may assume that the benefit in respect of the furnished flat is ￡11,800 peryear. (3 marks)

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考题 (b) (i) State the condition that would need to be satisfied for the exercise of Paul’s share options in Memphisplc to be exempt from income tax and the tax implications if this condition is not satisfied.(2 marks)

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考题 (ii) Calculate Paul’s tax liability if he exercises the share options in Memphis plc and subsequently sells theshares in Memphis plc immediately, as proposed, and show how he may reduce this tax liability.(4 marks)

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考题 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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考题 (b) For this part, assume today’s date is 1 May 2010.Bill and Ben decided not to sell their company, and instead expanded the business themselves. Ben, however,is now pursuing other interests, and is no longer involved with the day to day activities of Flower Limited. Billbelieves that the company would be better off without Ben as a voting shareholder, and wishes to buy Ben’sshares. However, Bill does not have sufficient funds to buy the shares himself, and so is wondering if thecompany could acquire the shares instead.The proposed price for Ben’s shares would be ￡500,000. Both Bill and Ben pay income tax at the higher rate.Required:Write a letter to Ben:(1) stating the income tax (IT) and/or capital gains tax (CGT) implications for Ben if Flower Limited were torepurchase his 50% holding of ordinary shares, immediately in May 2010; and(2) advising him of any available planning options that might improve this tax position. Clearly explain anyconditions which must be satisfied and quantify the tax savings which may result.(13 marks)Assume that the corporation tax rates for the financial year 2005 and the income tax rates and allowancesfor the tax year 2005/06 apply throughout this question.

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考题 (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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考题 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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考题 (ii) Advise Mr Fencer of the income tax implications of the proposed financing arrangements. (2 marks)

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考题 (b) Explain the corporation tax and value added tax (VAT) implications of the following aspects of the proposedrestructuring of the Rapier Ltd group.(i) The immediate tax implications of the restructuring. (6 marks)

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考题 (b) The directors of Carver Ltd are aware that some of the company’s shareholders want to realise the value in theirshares immediately. Accordingly, instead of investing in the office building or the share portfolio they areconsidering two alternative strategies whereby, following the sale of the company’s business, a payment will bemade to the company’s shareholders.(i) Liquidate the company. The payment by the liquidator would be ￡126 per share.(ii) The payment of a dividend of ￡125 per share following which a liquidator will be appointed. The paymentby the liquidator to the shareholders would then be ￡1 per share.The company originally issued 20,000 ￡1 ordinary shares at par value to 19 members of the Cutler family.Following a number of gifts and inheritances there are now 41 shareholders, all of whom are family members.The directors have asked you to attend a meeting to set out the tax implications of these two alternative strategiesfor each of the two main groups of shareholders: adults with shareholdings of more than 500 shares and childrenwith shareholdings of 200 shares or less.Required:Prepare notes explaining:– the amount chargeable to tax; and– the rates of tax that will applyin respect of each of the two strategies for each of the two groups of shareholders ready for your meetingwith the directors of Carver Ltd. You should assume that none of the shareholders will have any capitallosses either in the tax year 2007/08 or brought forward as at 5 April 2007. (10 marks)Note:You should assume that the rates and allowances for the tax year 2006/07 will continue to apply for theforeseeable future.

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考题 6 Sergio and Gerard each inherited a half interest in a property, ‘Hilltop’, in October 2005. ‘Hilltop’ had a probate valueof ￡124,000, but in November 2005 it was badly damaged by fire. In January 2006 the insurance company madea payment of ￡81,700 each to Sergio and Gerard. In February 2006 Sergio and Gerard each spent ￡55,500 of theinsurance proceeds on restoring the property. ‘Hilltop’ was worth ￡269,000 following the restoration work. In July2006, Sergio and Gerard sold ‘Hilltop’ for ￡310,000.Sergio is 69 years old and a widower with three adult children and seven grandchildren. His annual income consistsof a pension of ￡9,900 and interest of ￡300 on savings of ￡7,600 in a bank deposit account. Sergio owns his homebut no other significant assets. He plans to buy a domestic rental property with the proceeds from the sale of ‘Hilltop’,such that on his death he will have a significant asset which can be sold and divided between the members of hisfamily.Gerard is 34 years old. He is employed by Fizz plc on a salary of ￡66,500 per year together with a performancerelated bonus. Gerard estimates that he will receive a bonus in December 2007 of ￡4,500, in line with previousyears, and that his taxable benefits in the tax year 2007/08 will amount to ￡7,140. He also expects to receivedividends from UK companies of ￡1,935 and bank interest of ￡648 in the tax year 2007/08. Gerard intends to setup a personal pension plan in August 2007. He has not made any pension contributions in the past and proposes touse part of the proceeds from the sale of ‘Hilltop’ to make the maximum possible tax allowable contribution.Fizz plc has announced that it intends to replace the performance related bonus scheme with a share incentive plan,also linked to performance, with effect from 6 April 2008. Gerard estimates that Fizz plc will award him free sharesworth ￡2,100 each year. He will also purchase partnership shares worth ￡700 each year and, as a result, will beawarded matching shares (further free shares) worth ￡1,400.Required:(a) Calculate the chargeable gains arising on the receipt of the insurance proceeds in January 2006 and the saleof ‘Hilltop’ in July 2006. You should assume that any elections necessary to minimise the gain on the receiptof the insurance proceeds have been submitted. (4 marks)

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考题 4 Coral is the owner and managing director of Reef Ltd. She is considering the manner in which she will make her firstpension contributions. In November 2007 she inherited her mother’s house in the country of Kalania.The following information has been extracted from client files and from telephone conversations with Coral.Coral:– 1972 – Born in the country of Kalania. Her father, who died in 2002, was domiciled in Kalania.– 1999 – Moved to the UK and has lived and worked here since then.– 2001 – Subscribed for 100% of the ordinary share capital of Reef Ltd.– Intends to sell Reef Ltd and return to live in the country of Kalania in 2012.– No income apart from that received from Reef Ltd.Reef Ltd:– A UK resident company with annual profits chargeable to corporation tax of approximately ￡70,000.– Four employees including Coral.– Provides scuba diving lessons to members of the public.Payments from Reef Ltd to Coral in 2007/08:– Director’s fees of ￡460 per month.– Dividends paid of ￡14,250 in June 2007 and ￡14,250 in September 2007.Pension contributions:– Coral has not so far made any pension contributions in the tax year 2007/08 but wishes to make gross pensioncontributions of ￡9,000.– The contributions are to be made by Reef Ltd or Coral or a combination of the two in such a way as to minimisethe total after tax cost.– Any contributions made by Coral will be funded by an additional dividend from Reef Ltd.House in the country of Kalania:– Beachfront property with potential rental income of ￡550 per month after deduction of allowable expenditure.– Coral will use it for holidays for two months each year.The tax system in the country of Kalania:– No capital gains tax or inheritance tax.– Income tax at 8% on income arising in the country of Kalania.– No double tax treaty with the UK.Required:(a) With the objective of minimising the total after tax cost, advise Coral as to whether the gross pensioncontributions of ￡9,000 should be made:– wholly by Reef Ltd; or– by Coral to the extent that they are tax allowable with the balance made by Reef Ltd.Your answer should include supporting calculations where necessary. (9 marks)

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考题 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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考题 2 Assume that today’s date is 1 July 2005.Jan is aged 45 and single. He is of Danish domicile but has been working in the United Kingdom since 1 May 2004and intends to remain in the UK for the medium to long term. Although Jan worked briefly in the UK in 1986, hehas forgotten how UK taxation works and needs some assistance before preparing his UK income tax return.Jan’s salary from 1 May 2004 was ￡74,760 per annum. Jan also has a company car – a Jaguar XJ8 with a list priceof ￡42,550 including extras, and CO2 emissions of 242g/km. The car was available to him from 1 July 2004. Freepetrol is provided by the company. Jan has other taxable benefits amounting to ￡3,965.Jan’s other 2004/05 income comprises:￡Dividend income from UK companies (cash received) 3,240Interest received on an ISA account 230Interest received on a UK bank account 740Interest remitted from an offshore account (net of 15% withholding tax) 5,100Income remitted from a villa in Portugal (net of 45% withholding tax) 4,598The total interest arising on the offshore account was ￡9,000 (gross). In addition, Jan has not remitted otherPortuguese rental income arising in the year, totalling a further ￡1,500 (gross).Jan informs you that his employer is thinking of providing him with rented accommodation while he looks for a houseto buy. The accommodation would be a two bedroom flat, valued at ￡155,000 with an annual value of ￡6,000. Itwould be made available from 6 August 2005. The company will pay the rent of ￡600 per month for the first sixmonths. All other bills will be paid by Jan.Jan also informs you that he has 25,000 ordinary shares in Gilet Ltd (‘Gilet’), an unquoted UK trading company. Hehas held these shares since August 1986 when he bought 2,500 shares at ￡4.07 per share. In January 1994, abonus issue gave each shareholder nine shares for each ordinary share held. In the last week all Gilet’s shareholdershave received an offer from Jumper plc (‘Jumper’) who wishes to acquire the shares. Jumper has offered the following:– 3 shares in Jumper (currently trading at ￡3.55 per share) for every 5 shares in Gilet, and– 25p cash per shareRequired:(a) Calculate Jan’s 2004/05 income tax (IT) payable. (11 marks)

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考题 JJG Co is planning to raise $15 million of new finance for a major expansion of existing business and is considering a rights issue, a placing or an issue of bonds. The corporate objectives of JJG Co, as stated in its Annual Report, are to maximise the wealth of its shareholders and to achieve continuous growth in earnings per share. Recent financial information on JJG Co is as follows:Required:(a) Evaluate the financial performance of JJG Co, and analyse and discuss the extent to which the company has achieved its stated corporate objectives of:(i) maximising the wealth of its shareholders;(ii) achieving continuous growth in earnings per share.Note: up to 7 marks are available for financial analysis.(12 marks)(b) If the new finance is raised via a rights issue at $7·50 per share and the major expansion of business hasnot yet begun, calculate and comment on the effect of the rights issue on:(i) the share price of JJG Co;(ii) the earnings per share of the company; and(iii) the debt/equity ratio. (6 marks)(c) Analyse and discuss the relative merits of a rights issue, a placing and an issue of bonds as ways of raising the finance for the expansion. (7 marks)

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考题 (a) The following figures have been calculated from the financial statements (including comparatives) of Barstead forthe year ended 30 September 2009:increase in profit after taxation 80%increase in (basic) earnings per share 5%increase in diluted earnings per share 2%Required:Explain why the three measures of earnings (profit) growth for the same company over the same period cangive apparently differing impressions. (4 marks)(b) The profit after tax for Barstead for the year ended 30 September 2009 was $15 million. At 1 October 2008 the company had in issue 36 million equity shares and a $10 million 8% convertible loan note. The loan note will mature in 2010 and will be redeemed at par or converted to equity shares on the basis of 25 shares for each $100 of loan note at the loan-note holders’ option. On 1 January 2009 Barstead made a fully subscribed rights issue of one new share for every four shares held at a price of $2·80 each. The market price of the equity shares of Barstead immediately before the issue was $3·80. The earnings per share (EPS) reported for the year ended 30 September 2008 was 35 cents.Barstead’s income tax rate is 25%.Required:Calculate the (basic) EPS figure for Barstead (including comparatives) and the diluted EPS (comparatives not required) that would be disclosed for the year ended 30 September 2009. (6 marks)

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