(ii) Briefly outline the tax consequences for Henry if the types of protection identified in (i) were to beprovided for him by Happy Home Ltd compared to providing them for himself. You are not required todiscuss the corporation tax (CT) consequences for Happy Home Ltd. (4 marks)

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 (c) Assuming that Stuart:(i) purchased 201,000 shares in Omega plc on 3 December 2005; and(ii) dies on 20 December 2007,calculate the potential inheritance tax (IHT) liability which would arise if Rebecca were to die on 1 March2008, and no further tax planning measures were taken.Assume that all asset values remain unchanged and that the current rates of inheritance tax continue toapply. (6 marks)

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考题 (ii) Illustrate the benefit of revising the corporate structure by calculating the corporation tax (CT) payablefor the year ended 31 March 2006, on the assumptions that:(1) no action is taken; and(2) an amended structure as recommended in (i) above is implemented from 1 June 2005. (3 marks)

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考题 Assume that the corporation tax rates for the financial year 2004 apply throughout.(b) Explain the corporation tax (CT) and value added tax (VAT) issues that Irroy should be aware of, if sheproceeds with her proposal for the Irish subsidiary, Green Limited. Your answer should clearly identify thosefactors which will determine whether or not Green Limited is considered UK resident or Irish resident andthe tax implications of each alternative situation.You need not repeat points that are common to each situation. (16 marks)

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考题 (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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考题 (c) State the tax consequences for both Glaikit Limited and Alasdair if he borrows money from the company, asproposed, on 1 January 2006. (3 marks)

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考题 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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考题 (b) Calculate the corporation tax (CT) liabilities for Alantech Ltd, Boron Ltd and Bubble Ltd for the year ending31 December 2004 on the assumption that loss reliefs are taken as early as possible. (9 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 (b) Identify the most appropriate approved share option scheme for Happy Home Ltd. Outline the schemerequirements and the tax benefits of using it compared to the current unapproved scheme. (6 marks)

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考题 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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考题 (c) Calculate the expected corporation tax liability of Dovedale Ltd for the year ending 31 March 2007 on theassumption that all available reliefs are claimed by Dovedale Ltd but that Hira Ltd will not claim any capitalallowances in that year. (4 marks)

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考题 (ii) Compute the annual income tax saving from your recommendation in (i) above as compared with thesituation where Cindy retains both the property and the shares. Identify any other tax implicationsarising from your recommendation. Your answer should consider all relevant taxes. (3 marks)

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考题 (b) (i) Compute the corporation tax liability of Speak Write Ltd for its first trading period on the assumptionthat the IR 35 legislation applies to all of its income. (2 marks)

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考题 (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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考题 (ii) Calculate the corporation tax (CT) payable by Tay Limited for the year ended 31 March 2006, takingadvantage of all available reliefs. (3 marks)

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考题 (c) Briefly outline the corporation tax (CT) issues that Tay Limited should consider when deciding whether toacquire the shares or the assets of Tagus LDA. You are not required to discuss issues relating to transferpricing. (7 marks)

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考题 (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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考题 (ii) The UK value added tax (VAT) implications for Razor Ltd of selling tools to and purchasing tools fromCutlass Inc; (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 (iii) The effect of the restructuring on the group’s ability to recover directly and non-directly attributable inputtax. (6 marks)You are required to prepare calculations in respect of part (ii) only of this part of this question.Note: – You should assume that the corporation tax rates and allowances for the financial year 2006 applythroughout this question.

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考题 (b) Explain why making sales of Sabals in North America will have no effect on Nikau Ltd’s ability to recover itsinput tax. (3 marks)Notes: – you should assume that the corporation tax rates and allowances for the financial year to 31 March 2007will continue to apply for the foreseeable future.– you should ignore indexation allowance.

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考题 (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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考题 (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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考题 (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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考题 (ii) Write a letter to Donald advising him on the most tax efficient manner in which he can relieve the lossincurred in the year to 31 March 2007. Your letter should briefly outline the types of loss relief availableand explain their relative merits in Donald’s situation. Assume that Donald will have no source of incomeother than the business in the year of assessment 2006/07 and that any income he earned on a parttimebasis while at university was always less than his annual personal allowance. (9 marks)Assume that the corporation tax rates and allowances for the financial year 2004 and the income tax ratesand allowances for 2004/05 apply throughout this question.Relevant retail price index figures are:January 1998 159·5April 1998 162·6

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考题 You are the Exchange administrator for the Xxx Corporation’s Exchange 2010 organization.People from outside your organization make inquiries to the Xxx’s Tax department.You create a Tax distribution group that contains all members of the Tax department so people can send questions to the members of the department.You have a number of additional requirements：（1）Only authorized questions should be sent to the Tax department.You must determine what an authorized question is. （2）All users in the Tax department， except the department supervisor named George， must receive authorized questions. （3）George must be able to send feedback to the Tax department. What should you do？（）A、Check Messages sent to this group have to be approved by a moderator on the properties page of the Tax distribution groupB、Add George’s account as group moderator of the Tax distribution group Leading the way in IT testing and certification tools，C、Remove George’s account from the Tax distribution group， add him to another distribution group， and add that group as a member of the Tax distribution groupD、Add George’s account as a sender that does not require message approvalE、Check Notify senders in your organization only when their messages aren’t approved

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