(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)
(ii) Analyse the effect of delaying the sale of the business of the Stiletto Partnership to Razor Ltd until
30 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)
相关考题：
(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)
(ii) Calculate her income tax (IT) and national insurance (NIC) payable for the year of assessment 2006/07.(4 marks)
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)
(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)
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)
(b) Explain the advantages from a tax point of view of operating the new business as a partnership rather thanas a company whilst it is making losses. You should calculate the tax adjusted trading loss for the yearending 31 March 2008 for both situations and indicate the years in which the loss relief will be obtained.You are not required to prepare any other supporting calculations. (10 marks)
(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)
(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.
(ii) The UK value added tax (VAT) implications for Razor Ltd of selling tools to and purchasing tools fromCutlass Inc; (2 marks)
(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.
(c) Calculate and explain the amount of income tax relief that Gerard will obtain in respect of the pensioncontributions he proposes to make in the tax year 2007/08 and contrast this with how his position could beimproved by delaying some of the contributions that he could have made in 2007/08 until 2008/09. Youshould include relevant supporting calculations and quantify the additional tax savings arising as a result ofyour advice.You should ignore the proposed changes to the bonus scheme for this part of this question and assume thatGerard’s income will not change in 2008/09. (12 marks)
3 Palm plc recently acquired 100% of the ordinary share capital of Nikau Ltd from Facet Ltd. Palm plc intends to useNikau Ltd to develop a new product range, under the name ‘Project Sabal’. Nikau Ltd owns shares in a non-UKresident company, Date Inc.The following information has been extracted from client files and from a meeting with the Finance Director of Palmplc.Palm plc:– Has more than 40 wholly owned subsidiaries such that all group companies pay corporation tax at 30%.– All group companies prepare accounts to 31 March.– Acquired Nikau Ltd on 1 November 2007 from Facet Ltd, an unrelated company.Nikau Ltd:– UK resident company that manufactures domestic electronic appliances for sale in the European Union (EU).– Large enterprise for the purposes of the enhanced relief available for research and development expenditure.– Trading losses brought forward as at 1 April 2007 of ￡195,700.– Budgeted taxable trading profit of ￡360,000 for the year ending 31 March 2008 before taking account of ‘ProjectSabal’.– Dividend income of ￡38,200 will be received in the year ending 31 March 2008 in respect of the shares in DateInc.‘Project Sabal’:– Development of a range of electronic appliances, for sale in North America.– Project Sabal will represent a significant advance in the technology of domestic appliances.– Nikau Ltd will spend ￡70,000 on staffing costs and consumables researching and developing the necessarytechnology between now and 31 March 2008. Further costs will be incurred in the following year.– Sales to North America will commence in 2009 and are expected to generate significant profits from that year.Shares in Date Inc:– Nikau Ltd owns 35% of the ordinary share capital of Date Inc.– The shares were purchased from Facet Ltd on 1 June 2003 for their market value of ￡338,000.– The sale was a no gain, no loss transfer for the purposes of corporation tax.– Facet Ltd purchased the shares in Date Inc on 1 March 1994 for ￡137,000.Date Inc:– A controlled foreign company resident in the country of Palladia.– Annual chargeable profits arising out of property investment activities are approximately ￡120,000, of whichapproximately ￡115,000 is distributed to its shareholders each year.The tax system in Palladia:– No taxes on income or capital profits.– 4% withholding tax on dividends paid to shareholders resident outside Palladia.Required:(a) Prepare detailed explanatory notes, including relevant supporting calculations, on the effect of the followingissues on the amount of corporation tax payable by Nikau Ltd for the year ending 31 March 2008.(i) The costs of developing ‘Project Sabal’ and the significant commercial changes to the company’sactivities arising out of its implementation. (8 marks)
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)
(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.
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)
(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)
(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)
(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
6 Charles and Jane Miro, aged 31 and 34 years respectively, have been married for ten years and have two childrenaged six and eight years. Charles is a teacher but for the last five years he has stayed at home to look after theirchildren. Jane works as a translator for Speak Write Ltd.Speak Write Ltd was formed and began trading on 6 April 2006. It provides translation services to universities. Jane,who ceased employment with Barnham University to found the company, owns 100% of its ordinary share capitaland is its only employee.Speak Write Ltd has translated documents for four different universities since it began trading. Its biggest client isBarnham University which represents 70% of the company’s gross income. It is estimated that the company’s grossfee income for its first 12 months of trading will be ￡110,000. Speak Write Ltd usually agrees fixed fees in advancewith its clients although it charges for some projects by reference to the number of days taken to do the work. Noneof the universities makes any payment to Speak Write Ltd in respect of Jane being on holiday or sick.All of the universities insist that Jane does the work herself. Jane carries out the work for three of the universities inher office at home using a computer and specialised software owned by Speak Write Ltd. The work she does forBarnham University is done in the university’s library on one of its computers as the documents concerned are toodelicate to move.The first set of accounts for Speak Write Ltd will be drawn up for the year ending 5 April 2007. It is estimated thatthe company’s tax adjusted trading profit for this period will be ￡52,500. This figure is after deducting Jane’s salaryof ￡4,000 per month and the related national insurance contributions but before any adjustments required by theapplication of the personal service companies (IR 35) legislation. The company has no other sources of income orcapital gains.Jane has not entered into any communication with HM Revenue and Customs (HMRC) with respect to the companyand wants to know:– When the corporation tax computation should be submitted and when the tax is due.– When the corporation tax computation can be regarded as having been agreed by HMRC.Charles and Jane have requested a meeting to discuss the family’s finances. In particular, they wish to consider theshortfall in the family’s annual income and any other related issues if Jane were to die. Their mortgage is coveredby a term assurance policy but neither of them have made any pension contributions or carried out any other longterm financial planning.Jane has estimated that her annual after tax income from Speak Write Ltd, on the assumption that she extracts all ofthe company’s profits, will be ￡58,000. Charles owns two investment properties that together generate after taxincome of ￡8,500. He estimates that he could earn ￡28,000 after tax if he were to return to work.The couple’s annual surplus income, after payment of all household expenditure including mortgage payments of￡900 per month, is ￡21,000. Charles and Jane have no other sources of income.Required:(a) Write a letter to Jane setting out:(i) the arguments that HMRC could put forward, based only on the facts set out above, in support ofapplying the IR 35 legislation to Speak Write Ltd; and(ii) the additional income tax and national insurance contributions that would be payable, together withtheir due date of payment, if HMRC applied the IR 35 legislation to all of the company’s income in2006/07. (11 marks)
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)
听力原文：The tax return does not show accrued income.(8)A．The tax return is not shown in the income.B．The income is not accurate in taxation.C．The tax should be returned according to the income.D．The tax return is not in accordance with the income that should be taxed.
Income tax【个人所得税】 For many young Americans, graduating from college means finding a job, moving out of the dorm room and beginning to register one's annual earnings with the US government. That last item is the law, though sometimes it's a hassle(难事)to obey. Independent tax advisor Bob Gilbert calls the US income tax system "amazingly complicated". But he adds that "very little of the complicated tax law applies to young people who are just beginning their careers". According to Gilbert, 80 to 90 percent of Americans are not really burdened by the system's complications. Still, all the numbers and forms can be a little confusing to those who are just starting their careers. Some pull out their calculators and try to do the math alone. Some use income tax software. Others just hand the whole responsibility over to tax firms like Gilbert's. According to income tax law expert Linda Beale, young people will often follow their parents' lead when filling their income forms. "Young people who grow up in wealthy households typically use professional tax services because their parents have always done so," said Beale, a professor at Wayne State University in Michigan State. "On the other hand, most poorer young people probably try to do their own taxes, unless they want a quick 'refund' with the help of a tax advisor". In fact, obeying the law has its benefits. For one, many young people can expect a tax refund. This means that, over the course of the year, they have paid too much in monthly federal or state taxes and are entitled to the difference. Bob Thalman, a 20-year-old university student, expects he will get a refund of about 100, which will probably go in the bank, or perhaps be used to pay for car insurance or credit card bills. Thalman called the whole process a "hassle", but added that he didn't wat to test the law by not filling his income tax papers. "I'm worried about what would happen if I failed to file," he said. "I know one individual who did not report his income tax for many years, and he's now in federal prison. I certainly don’t want that."文章(16~22)A college student with a part-time job is not required to file an income tax form.A.RightB.WrongC.Not mentioned
Income Income may be national income and personal income. Whereas national income is defined as the total earned income of all the factors of production-namely, profits, interest, rent, wages, and other compensation for labor, personal income may be defined as total money income received by individuals before personal taxes are paid. National income does not equal GNP (Gross National Product) because the factors of production do not receive payment for either capital consumption allowances or indirect business taxes, both of which are included in GNP. The money put aside for capital consumption is for replacement and thus is not counted as income. Indirect taxes include sales taxes, property taxes , and excise taxes that are paid by businesses directly to the government and so reduce the income left to pay for the factors of production. Three-fourths of national income goes for wages, salaries, and other forms of compensation to employees. Whereas national income shows the income that the factors of production earn, personal income measures the income that individuals or households receive. Corporation profits are included in national income because they are earned. Out of these profits, however, corporation profit taxes must be paid to the government, and some money must be put into the business for expansion. Only that part of profits distributed as dividends goes to the individual; therefore, out of corporation profits only dividends count as personal income. The factors of production earn money for social security and unemployment insurance contributions, but this money goes to government (which is not a factor of production), not to individuals. It is therefore part of national income but not part of personal income. On the other hand, money received by individuals when they collect social security or unemployment compensation is not money earned but money received. Interest received on government bonds is also in this category, because much of the money received from the sale of bonds went to pay for war production and that production no longer furnishes a service to the economy. The money people receive as personal income may be either spent or saved. However, not all spending is completely voluntary. A significant portion of our income goes to pay personal taxes. Most workers never receive the money they pay in personal taxes, because it is withheld from their paychecks. The money that individuals are left with after they have met their tax obligations is disposable personal income. Disposable income can be divided between personal consumption expenditures and personal savings. It is important to remember that personal saving is what is left after spending.It can be easily seen from this passage that the government levies tax on（）A、corporation profitsB、every individual even though his income is very lowC、those who work in joint venturesD、those who work in government departments
单选题Income tax rates are（）to one's annual income.ArelatedBdependentCbasedDassociated