(c) (i) Explain the inheritance tax (IHT) implications and benefits of Alvaro Pelorus varying the terms of hisfather’s will such that part of Ray Pelorus’s estate is left to Vito and Sophie. State the date by which adeed of variation would need to be made in order for it to be valid; (3 marks)
(c) (i) Explain the inheritance tax (IHT) implications and benefits of Alvaro Pelorus varying the terms of his
father’s will such that part of Ray Pelorus’s estate is left to Vito and Sophie. State the date by which a
deed of variation would need to be made in order for it to be valid; (3 marks)
相关考题：
(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)
(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)
(d) Advise on any lifetime inheritance tax (IHT) planning that could be undertaken in respect of both Stuart andRebecca to help reduce the potential inheritance tax (IHT) liability calculated in (c) above. (7 marks)Relevant retail price index figures are:May 1994 144·7April 1998 162·6
(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)
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)
(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)
(b) (i) Calculate the inheritance tax (IHT) that will be payable if Debbie were to die today (8 June 2005).Assume that no tax planning measures are taken and that there has been no change in the value of anyof the assets since David’s death. (4 marks)
(ii) State when the inheritance tax (IHT) calculated in (i) would be payable and by whom. (2 marks)
(c) Assuming that she will survive until July 2009, advise on the lifetime inheritance tax (IHT) planningmeasures that could be undertaken by Debbie, quantifying the savings that can be made. (7 marks)For this question you should assume that the rates and allowances for 2004/05 apply throughout.
(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)
(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)
(c) Without changing the advice you have given in (b), or varying the terms of Luke’s will, explain how Mabelcould further reduce her eventual inheritance tax liability and quantify the tax saving that could be made.(3 marks)The increase in the retail prices index from April 1984 to April 1998 is 84%.You should assume that the rates and allowances for the tax year 2005/06 will continue to apply for theforeseeable future.
(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.
(b) Calculate the inheritance tax (IHT) liability arising as a result of Christopher’s death. (11 marks)
(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)
(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.
(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.
1 Alvaro Pelorus is 47 years old and married to Maria. The couple have two children, Vito and Sophie, aged 22 and19 years respectively. Alvaro and Maria have lived in the country of Koruba since 1982. On 1 July 2005 the familymoved to the UK to be near Alvaro’s father, Ray, who was very ill. Alvaro and Maria are UK resident, but not ordinarilyresident in the tax years 2005/06 and 2006/07. They are both domiciled in the country of Koruba.On 1 February 2007 Ray Pelorus died. He was UK domiciled, having lived in the UK for the whole of his life. For thepurposes of inheritance tax, his death estate consisted of UK assets, valued at ￡870,000 after deduction of allavailable reliefs, and a house in the country of Pacifica valued at ￡94,000. The executors of Ray’s estate have paidPacifican inheritance tax of ￡1,800 and legal fees of ￡7,700 in respect of the sale of the Pacifican house. Ray leftthe whole of his estate to Alvaro.Ray had made two gifts during his lifetime:(i) 1 May 2003: He gave Alvaro 95 acres of farm land situated in the UK. The market value of the land was￡245,000, although its agricultural value was only ￡120,000. Ray had acquired the land on1 January 1996 and granted an agricultural tenancy on that date. Alvaro continues to own theland as at today’s date and it is still subject to the agricultural tenancy.(ii) 1 August 2005: He gave Alvaro 6,000 shares valued at ￡183,000 in Pinger Ltd, a UK resident tradingcompany. Gift relief was claimed in respect of this gift. Ray had acquired 14,000 shares inPinger Ltd on 1 April 1997 for ￡54,600.You may assume that Alvaro is a higher rate taxpayer for the tax years 2005/06 and 2006/07. In 2006/07 he madethe following disposals of assets:(i) On 1 July 2006 he sold the 6,000 shares in Pinger Ltd for ￡228,000.(ii) On 1 September 2006 he sold 2,350 shares in Lapis Inc, a company resident in Koruba, for ￡8,270. Alvarohad purchased 5,500 shares in the company on 1 September 2002 for ￡25,950.(iii) On 1 December 2006 he transferred shares with a market value of ￡74,000 in Quad plc, a UK quoted company,to a UK resident discretionary trust for the benefit of Vito and Sophie. Alvaro had purchased these shares on1 January 2006 for ￡59,500.Alvaro has not made any other transfers of value for the purposes of UK inheritance tax. He owns the family housein the UK as well as shares in UK and Koruban companies and commercial rental property in the country of Koruba.Maria has not made any transfers of value for the purposes of UK inheritance tax. Her only significant asset is thefamily home in the country of Koruba.Alvaro and his family expect to return to their home in the country of Koruba in October 2007 once Ray’s affairs havebeen settled. There is no double taxation agreement between the UK and Koruba.Required:(a) Calculate the inheritance tax (IHT) payable as a result of the death of Ray Pelorus. Explain the availabilityor otherwise of agricultural property relief and business property relief on the two lifetime gifts made by Ray.(8 marks)
(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)
(b) Draft a report as at today’s date advising Cutlass Inc on its proposed activities. The report should cover thefollowing issues:(i) The rate at which the profits of Cutlass Inc will be taxed. This section of the report should explain:– the company’s residency position and what Ben and Amy would have to do in order for the companyto be regarded as resident in the UK under the double tax treaty;– the meaning of the term ‘permanent establishment’ and the implications of Cutlass Inc having apermanent establishment in Sharpenia;– the rate at which the profits of Cutlass Inc will be taxed on the assumption that it is resident in theUK under the double tax treaty and either does or does not have a permanent establishment inSharpenia. (9 marks)
(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)
(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)
(b) State the immediate tax implications of the proposed gift of the share portfolio to Avril and identify analternative strategy that would achieve Crusoe’s objectives whilst avoiding a possible tax liability in thefuture. State any deadline(s) in connection with your proposed strategy. (5 marks)
(ii) Explain why Galileo is able to pay the inheritance tax due in instalments, state when the instalments aredue and identify any further issues relevant to Galileo relating to the payments. (3 marks)
James died on 22 January 2015. He had made the following gifts during his lifetime:(1) On 9 October 2007, a cash gift of ￡35,000 to a trust. No lifetime inheritance tax was payable in respect of this gift.(2) On 14 May 2013, a cash gift of ￡420,000 to his daughter.(3) On 2 August 2013, a gift of a property valued at ￡260,000 to a trust. No lifetime inheritance tax was payable in respect of this gift because it was covered by the nil rate band. By the time of James’ death on 22 January 2015, the property had increased in value to ￡310,000.On 22 January 2015, James’ estate was valued at ￡870,000. Under the terms of his will, James left his entire estate to his children.The nil rate band of James’ wife was fully utilised when she died ten years ago.The nil rate band for the tax year 2007–08 is ￡300,000, and for the tax year 2013–14 it is ￡325,000.Required:(a) Calculate the inheritance tax which will be payable as a result of James’ death, and state who will be responsible for paying the tax. (6 marks)(b) Explain why it might have been beneficial for inheritance tax purposes if James had left a portion of his estate to his grandchildren rather than to his children. (2 marks)(c) Explain why it might be advantageous for inheritance tax purposes for a person to make lifetime gifts even when such gifts are made within seven years of death.Notes:1. Your answer should include a calculation of James’ inheritance tax saving from making the gift of property to the trust on 2 August 2013 rather than retaining the property until his death.2. You are not expected to consider lifetime exemptions in this part of the question. (2 marks)
问答题Inheritance tax is a tax which many countries levy on the total taxable value of the estate of a deceased person. Inheritance tax is paid by the inheritor of the estate or by the person in charge of its assets. In most cases, if the estate is left to a charitable organization or a surviving spouse, no inheritance tax is due. In China, inheritance tax does not exist. Should inheritance tax be introduced to China? The controversy that has raged over levying inheritance tax in China currently shows little sign of abating. The following are opinions from both sides. Read the excerpt carefully and write your response in about 300 words, in which you should: 1. summarize briefly the opinions from both sides, and then 2. give your comment. Marks will be awarded for content relevance, content sufficiency, organization and language quality. Failure to follow the above instructions may result in a loss of marks. Opponents of inheritance tax typically refer to it as “death tax.” They argue first that concern over burdening their children with this tax may lead elderly to make unwise investment decisions late in life, and that it may also discourage entrepreneurship earlier in life. Opponents also claim that morally it should be only the choice of the person who earned the money what should be done with it, not the government. They see taxing wealth at death as a kind of forced income redistribution that goes against the market economy. Proponents of inheritance tax say that it helps prevent consolidation of wealth in the hands of a few powerful families and is a basic building block of the nation’s system of taxation. They also feel that inheriting large sums without tax undermines people’s motives to work hard in the future and, thus, undercuts the principles of the market economy, encouraging people to become idle and unproductive, which hurts the country overall.