(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)
(b) (i) Advise Andrew of the income tax (IT) and capital gains tax (CGT) reliefs available on his investment in
the 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 investors
to obtain the maximum relief. (13 marks)
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(b) Explain the capital gains tax (CGT) and inheritance tax (IHT) implications of Graeme gifting his remaining ‘T’ordinary shares at their current value either:(i) to his wife, Catherine; or(ii) to his son, Barry.Your answer should be supported by relevant calculations and clearly identify the availability and effect ofany reliefs (other than the CGT annual exemption) that might be used to reduce or defer any tax liabilitiesarising. (9 marks)
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)
(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)
6 Alasdair, aged 42, is single. He is considering investing in property, as he has heard that this represents a goodinvestment. In order to raise the funds to buy the property, he wants to extract cash from his personal company, BeezerLimited, whose year end is 31 December.Beezer Limited was formed on 1 May 1998 with ￡1,000 of capital issued as 1,000 ￡1 ordinary shares, and tradeduntil 1 January 2005 when Alasdair sold the trade and related assets. The company’s only asset is cash of￡120,000. Alasdair wants to extract this cash from the company with the minimum amount of tax payable. He isconsidering either, paying himself a dividend of ￡120,000, on 31 March 2006, after which the company would haveno assets and be wound up or, leaving the cash in the company and then liquidating the company. Costs of liquidationof ￡5,000 would then be incurred.Since Beezer Limited ceased trading, Alasdair has been taken on as a partner at a marketing firm, Gallus Co. Heestimates his profit share for the year of assessment 2005/06 will be ￡30,000. He has not made any capital disposalsin the current tax year.Alasdair wishes to reinvest the cash extracted from Beezer Limited in property but is not sure whether he should investdirectly in residential or commercial property, or do so via some form. of collective investment. He is aware that Gallus Co are looking to rent a new warehouse which could be bought for ￡200,000. Alasdair thinks that he may be ableto buy the warehouse himself and lease it to his firm, but only if he can borrow the additional money to buy theproperty.Alasdair has a 25% shareholding in another company, Glaikit Limited, whose year end is 31 March. The remainingshares in this company are held by his friend, Gill. Alasdair is considering borrowing ￡15,000 from Glaikit Limitedon 1 January 2006. He does not intend to pay any interest on the loan, which is likely to be written off some timein 2007. Alasdair does not have any connection with Glaikit Limited other than his shareholding.Required:(a) Advise Alasdair whether or not a dividend payment will result in a higher after-tax cash sum than theliquidation of Beezer Limited. Assume that either the dividend would be paid on 31 March 2006 or theliquidation would take place on 31 March 2006. (9 marks)Assume that Beezer Limited has always paid corporation tax at or above the small companies rate of 19%and that the tax rates and allowances for 2004/05 apply throughout this part.
(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)
(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)
(b) Assuming that the income from the sale of the books is not treated as trading income, calculate Bob’s taxableincome and gains for all relevant tax years, using any loss reliefs in the most tax-efficient manner. Youranswer should include an explanation of the loss reliefs available and your reasons for using (or not using)them. (12 marks)Assume that the rates and allowances for 2004/05 apply throughout this part of the question.
(c) Advise Alan on the proposed disposal of the shares in Mobile Ltd. Your answer should include calculationsof the potential capital gain, and explain any options available to Alan to reduce this tax liability. (7 marks)
(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)
(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)
(c) Outline the ways in which Arthur and Cindy can reduce their income tax liability by investing in unquotedshares and recommend, with reasons, which form. of investment best suits their circumstances. You are notrequired to discuss the qualifying conditions applicable to the investment vehicle recommended. (5 marks)You should assume that the income tax rates and allowances for the tax year 2005/06 apply throughout thisquestion
(c) (i) Compute Gloria’s capital gains tax liability for 2006/07 ignoring any claims or elections available toreduce the liability. (3 marks)
(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.
(c) Prepare brief notes for the proposed meeting with Charles and Jane. Clearly identify the further informationyou would need in order to advise them more fully and suggest appropriate personal financial planningprotection products, in respect of both death and serious illness. (9 marks)You should assume that the income tax rates and allowances for the tax year 2005/06 and the corporation taxrates for the financial year 2005 apply throughout this question.
(ii) Assuming the relief in (i) is available, advise Sharon on the maximum amount of cash she could receiveon incorporation, without triggering a capital gains tax (CGT) liability. (3 marks)
(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.
(c) For commercial reasons, Damian believes that it would be sensible to place a new holding company, Bold plc,over the existing company, Linden Limited. Bold plc would also be unquoted and would acquire the existingLinden Limited shares in exchange for the issue of its own shares.If the new structure is implemented, Bold plc will provide management services to Linden Limited, but theamount that will be charged for these services is yet to be determined.Required:(i) State the capital gains tax (CGT) issues that Damian should be aware of before disposing of his sharesin Linden Limited to Bold plc. Your answer should include details of any conditions that will need to besatisfied if an immediate charge to tax is to be avoided. (4 marks)
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)
(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.
(b) Advise on the capital gains implications should Trent Limited’s old building be sold as proposed. Support youradvice with relevant calculations. (4 marks)
(ii) Advise Andrew of the tax implications arising from the disposal of the 7% Government Stock, clearlyidentifying the tax year in which any liability will arise and how it will be paid. (3 marks)
(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)
(ii) Advise Clifford of the capital gains tax implications of the alternative of selling the Oxford house andgarden by means of two separate disposals as proposed. Calculations are not required for this part ofthe question. (3 marks)
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)
(b) Prepare a reasoned explanation of how any capital gains tax arising in the UK on the sale of the paintingscan be minimised. (2 marks)
(c) (i) Calculate Benny’s capital gains tax liability for 2006/07. (6 marks)