(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)
(b) (i) State the condition that would need to be satisfied for the exercise of Paul’s share options in Memphis
plc to be exempt from income tax and the tax implications if this condition is not satisfied.
(2 marks)
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(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)
(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) State when the inheritance tax (IHT) calculated in (i) would be payable and by whom. (2 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.
(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)
(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)
(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)
(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) (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)
(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)
(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.
(iii) State the value added tax (VAT) and stamp duty (SD) issues arising as a result of inserting Bold plc asa holding company and identify any planning actions that can be taken to defer or minimise these taxcosts. (4 marks)You should assume that the corporation tax rates for the financial year 2005 and the income tax ratesand 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.
(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) (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)
(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)
(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) Advise Mr Fencer of the income tax implications of the proposed financing arrangements. (2 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)
(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.
(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) State, with reasons, whether Messier Ltd can provide Galileo with accommodation in the UK withoutgiving rise to a UK income tax liability. (2 marks)
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