(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)
(b) State the immediate tax implications of the proposed gift of the share portfolio to Avril and identify an
alternative strategy that would achieve Crusoe’s objectives whilst avoiding a possible tax liability in the
future. State any deadline(s) in connection with your proposed strategy. (5 marks)
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(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)
(ii) State when the inheritance tax (IHT) calculated in (i) would be payable and by whom. (2 marks)
(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)
(b) Mabel has two objectives when making the gifts to Bruce and Padma:(1) To pay no tax on any gift in her lifetime; and(2) To reduce the eventual liability to inheritance tax on her death.Advise Mabel which item to gift to Bruce and to Padma in order to satisfy her objectives. Give reasons foryour advice.Your advice should include a computation of the inheritance tax saved as a result of the two gifts, on theassumption that Mabel dies on 30 June 2011. (10 marks)
(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.
(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)
(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) 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)
(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) Calculate Alvaro Pelorus’s capital gains tax liability for the tax year 2006/07 on the assumption that allavailable reliefs are claimed. (8 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) 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)
(ii) Any increase or decrease in the group’s budgeted corporation tax liability for the year ending 30 June2008 due to the restructuring on the assumption that trading losses will be used as efficiently aspossible. (8 marks)
(b) The directors of Carver Ltd are aware that some of the company’s shareholders want to realise the value in theirshares immediately. Accordingly, instead of investing in the office building or the share portfolio they areconsidering two alternative strategies whereby, following the sale of the company’s business, a payment will bemade to the company’s shareholders.(i) Liquidate the company. The payment by the liquidator would be ￡126 per share.(ii) The payment of a dividend of ￡125 per share following which a liquidator will be appointed. The paymentby the liquidator to the shareholders would then be ￡1 per share.The company originally issued 20,000 ￡1 ordinary shares at par value to 19 members of the Cutler family.Following a number of gifts and inheritances there are now 41 shareholders, all of whom are family members.The directors have asked you to attend a meeting to set out the tax implications of these two alternative strategiesfor each of the two main groups of shareholders: adults with shareholdings of more than 500 shares and childrenwith shareholdings of 200 shares or less.Required:Prepare notes explaining:– the amount chargeable to tax; and– the rates of tax that will applyin respect of each of the two strategies for each of the two groups of shareholders ready for your meetingwith the directors of Carver Ltd. You should assume that none of the shareholders will have any capitallosses either in the tax year 2007/08 or brought forward as at 5 April 2007. (10 marks)Note:You should assume that the rates and allowances for the tax year 2006/07 will continue to apply for theforeseeable future.
(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)
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)
(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)
(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)
Text 4 The EU's faltering progress towards a common system of taxing the huge revenues of the new digital giants lurched forward this morning as Margrethe Vestager,the EU commissioner in charge of competition,declared that Amazon had received unfair state aid from Luxembourg through its tax arrangements,and demanded that it pay￡250m in back taxes.At the same time,Ms Vestager announced that the European commission would haul Ireland up before the European court of justice for its failure to demand￡13bn of unpaid tax from Apple,identi{ied in an earlier investigation.The lwo events illusrrate the gulf between the commission,together with some of the EU's iargest economies,and smaller members such as Ireland and Luxembourg.Both Ireland and Luxembourg defend their tax arrangements.Ireland in particular welcomes the thousands of goocl jobs that the tech giants bring and has no desire to find ways of extracting more tax from thcm in case it drives them away.The Irish government also insists that taxation is a sovereign matter,not an arena for EU interference.（ ）thers are under pressure from voters who are outraged that any company can make so much profit in their country and pay so little tax on it.Revenue from Facebook's UK operations,it has emerged,nearly quadrupled last year t0 842m,through growth in digital ad sales;its corporation tax bill crept up from 4.2m t0 5.Im.The US inland revenue service is also keen to find transparent ways of taxing the new digital economy,and is watching jealously as the European commission draws up its plans,suspicious of any move that might be used by the tech giants to offset their US tax bills.Already,companies such as Google and Amazon hold billions of dollars in offshore funds,where ihey are out of reach of the taxman.The US defensiveness about its own tax revenues points to the need for a global rather than a merely European solution to the question of how,what and whcre to tax the digital economy,but progress through the Organization for Economic Co-operation and Development（OECD）is glacial,and would in any event only be advisory.The commission is still hoping to get agreement on a common corporate tax base that would help to identify the parameters of any new tax system,but progress has stalled because of complexities around double taxation.Meanwhile the American Chamber of Commerce in Europe（ACCE）is warning that any attempt to tax the tech giants more would threaten investment and expansion.But across most of the EU discontent is growing,not just over the failure to pay tax-which has already prompted some tech companies to become more transparent,and even pay more-but over many of their practices.The chief executive of the ride-hailing app Uber has been in London this week trying to patch up relations with Transport for London（TfL）.Margrethe Vestager is right:enforcing regulations works.The U.S.'s close attention to EU's tax plan making is mentioned to stress_____A.the OECD's failure to fulfill its obligationB.Google and Amazon's success outside the U.S.C.U.S.'s jealousy in European progress in tax reformD.the universality of digital economy taxation problem