(b) The tax relief available in respect of the anticipated trading losses, together with supporting calculations anda recommended structure for the business. (16 marks)
(b) The tax relief available in respect of the anticipated trading losses, together with supporting calculations and
a recommended structure for the business. (16 marks)
相关考题：
(b) Assuming that Thai Curry Ltd claims relief for its trading loss against total profits under s.393A ICTA 1988,calculate the company’s corporation tax liability for the year ended 30 September 2005. (10 marks)
(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)
(d) Draft a letter for Tim Blake to send to WM’s investors to include the following:(i) why you believe robust internal controls to be important; and(ii) proposals on how internal systems might be improved in the light of the overestimation of mallerite atWM.Note: four professional marks are available within the marks allocated to requirement (d) for the structure,content, style. and layout of the letter.(16 marks)
(b) Using the unit cost information available and your calculations in (a), prepare a financial analysis of thedecision strategy which TOC may implement with regard to the manufacture of each product. (6 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)
(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)
(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.
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)
(c) (i) Compute Gloria’s capital gains tax liability for 2006/07 ignoring any claims or elections available toreduce the liability. (3 marks)
(ii) Explain, with reasons, the relief available in respect of the fall in value of the shares in All Over plc,identify the years in which it can be claimed and state the time limit for submitting the claim.(3 marks)
(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) 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)
(ii) Calculate the corporation tax (CT) payable by Tay Limited for the year ended 31 March 2006, takingadvantage of all available reliefs. (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)
(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)
(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)
(iii) The extent to which Amy will be subject to income tax in the UK on her earnings in respect of dutiesperformed for Cutlass Inc and the travel costs paid for by that company. (5 marks)Appropriateness of format and presentation of the report and the effectiveness with which its advice iscommunicated. (2 marks)Note:You should assume that the income tax rates and allowances for the tax year 2006/07 and the corporation taxrates and allowances for the financial year 2006 apply throughout this questio
(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)
(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)
(d) Evaluate the effect on Gerard of the changes to be made by Fizz plc to its performance related bonus scheme.You should ignore the effect of any pension contributions to be made by Gerard in the future, consider boththe value and timing of amounts received by Gerard and include relevant supporting calculations.(5 marks)Note: – You should assume that the income tax rates and allowances for the tax year 2006/07 apply throughoutthis question.
(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) Explanatory notes, together with relevant supporting calculations, in connection with the loan. (8 marks)Additional marks will be awarded for the appropriateness of the format and presentation of the schedules, theeffectiveness with which the information is communicated and the extent to which the schedules are structured ina logical manner. (3 marks)Notes: – you should assume that the tax rates and allowances for the tax year 2006/07 and for the financial yearto 31 March 2007 apply throughout the question.– you should ignore value added tax (VAT).
(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)
(b) Calculate the amount of input tax that will be recovered by Vostok Ltd in respect of the new premises in theyear ending 31 March 2009 and explain, using illustrative calculations, how any additional recoverable inputtax will be calculated in future years. (5 marks)