(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)
(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 any
of the assets since David’s death. (4 marks)
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(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)
(ii) Illustrate the benefit of revising the corporate structure by calculating the corporation tax (CT) payablefor the year ended 31 March 2006, on the assumptions that:(1) no action is taken; and(2) an amended structure as recommended in (i) above is implemented from 1 June 2005. (3 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) Calculate her income tax (IT) and national insurance (NIC) payable for the year of assessment 2006/07.(4 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)
(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.
3 Assume that today’s date is 10 May 2005.You have recently been approached by Fred Flop. Fred is the managing director and 100% shareholder of FlopLimited, a UK trading company with one wholly owned subsidiary. Both companies have a 31 March year-end.Fred informs you that he is experiencing problems in dealing with aspects of his company tax returns. The companyaccountant has been unable to keep up to date with matters, and Fred also believes that mistakes have been madein the past. Fred needs assistance and tells you the following:Year ended 31 March 2003The corporation tax return for this period was not submitted until 2 November 2004, and corporation tax of ￡123,500was paid at the same time. Profits chargeable to corporation tax were stated as ￡704,300.A formal notice (CT203) requiring the company to file a self-assessment corporation tax return (dated 1 February2004) had been received by the company on 4 February 2004.A detailed examination of the accounts and tax computation has revealed the following.– Computer equipment totalling ￡50,000 had been expensed in the accounts. No adjustment has been made inthe tax computation.– A provision of ￡10,000 was made for repairs, but there is no evidence of supporting information.– Legal and professional fees totalling ￡46,500 were allowed in full without any explanation. Fred hassubsequently produced the following analysis:Analysis of legal professional fees￡Legal fees on a failed attempt to secure a trading loan 15,000Debt collection agency fees 12,800Obtaining planning consent for building extension 15,700Accountant’s fees for preparing accounts 14,000Legal fees relating to a trade dispute 19,000– No enquiry has yet been raised by the Inland Revenue.– Flop Ltd was a large company in terms of the Companies Act definition for the year in question.– Flop Ltd had taxable profits of ￡595,000 in the previous year.Year ended 31 March 2004The corporation tax return has not yet been submitted for this year. The accounts are late and nearing completion,with only one change still to be made. A notice requiring the company to file a self-assessment corporation tax return(CT203) dated 27 July 2004 was received on 1 August 2004. No corporation tax has yet been paid.1 – The computation currently shows profits chargeable to corporation tax of ￡815,000 before accountingadjustments, and any adjustments for prior years.– A company owing Flop Ltd ￡50,000 (excluding VAT) has gone into liquidation, and it is unlikely that any of thismoney will be paid. The money has been outstanding since 3 September 2003, and the bad debt will need tobe included in the accounts.1 Fred also believes there are problems in relation to the company’s VAT administration. The VAT return for the quarterended 31 March 2005 was submitted on 5 May 2005, and VAT of ￡24,000 was paid at the same time. The previousreturn to 31 December 2004 was also submitted late. In addition, no account has been made for the VAT on the baddebt. The VAT return for 30 June 2005 may also be late. Fred estimates the VAT liability for that quarter to be ￡8,250.Required:(a) (i) Calculate the revised corporation tax (CT) payable for the accounting periods ending 31 March 2003and 2004 respectively. Your answer should include an explanation of the adjustments made as a resultof the information which has now come to light. (7 marks)(ii) State, giving reasons, the due payment date of the corporation tax (CT) and the filing date of thecorporation tax return for each period, and identify any interest and penalties which may have arisen todate. (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) 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)
(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) Calculate the corporation tax (CT) payable by Tay Limited for the year ended 31 March 2006, takingadvantage of all available reliefs. (3 marks)
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)
(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) The inheritance tax payable by Adam in respect of the gift from his aunt. (4 marks)Additional marks will be awarded for the appropriateness of the format and presentation of the memorandum andthe effectiveness with which the information is communicated. (2 marks)Note: you should assume that the tax rates and allowances for the tax year 2006/07 will continue to apply for theforeseeable future.
(c) On the assumption that the administrators of Noland’s estate will sell quoted shares in order to fund theinheritance tax due as a result of his death, calculate the value of the quoted shares that will be available totransfer to Avril. You should include brief notes of your treatment of the house and the shares in Kurb Ltd.(9 marks)Note: you should assume that the tax rates and allowances for the tax year 2006/07 apply throughout thisquestion.
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.