3 Palm plc recently acquired 100% of the ordinary share capital of Nikau Ltd from Facet Ltd. Palm plc intends to useNikau Ltd to develop a new product range, under the name ‘Project Sabal’. Nikau Ltd owns shares in a non-UKresident company, Date Inc.The following information has been extracted from client files and from a meeting with the Finance Director of Palmplc.Palm plc:– Has more than 40 wholly owned subsidiaries such that all group companies pay corporation tax at 30%.– All group companies prepare accounts to 31 March.– Acquired Nikau Ltd on 1 November 2007 from Facet Ltd, an unrelated company.Nikau Ltd:– UK resident company that manufactures domestic electronic appliances for sale in the European Union (EU).– Large enterprise for the purposes of the enhanced relief available for research and development expenditure.– Trading losses brought forward as at 1 April 2007 of ￡195,700.– Budgeted taxable trading profit of ￡360,000 for the year ending 31 March 2008 before taking account of ‘ProjectSabal’.– Dividend income of ￡38,200 will be received in the year ending 31 March 2008 in respect of the shares in DateInc.‘Project Sabal’:– Development of a range of electronic appliances, for sale in North America.– Project Sabal will represent a significant advance in the technology of domestic appliances.– Nikau Ltd will spend ￡70,000 on staffing costs and consumables researching and developing the necessarytechnology between now and 31 March 2008. Further costs will be incurred in the following year.– Sales to North America will commence in 2009 and are expected to generate significant profits from that year.Shares in Date Inc:– Nikau Ltd owns 35% of the ordinary share capital of Date Inc.– The shares were purchased from Facet Ltd on 1 June 2003 for their market value of ￡338,000.– The sale was a no gain, no loss transfer for the purposes of corporation tax.– Facet Ltd purchased the shares in Date Inc on 1 March 1994 for ￡137,000.Date Inc:– A controlled foreign company resident in the country of Palladia.– Annual chargeable profits arising out of property investment activities are approximately ￡120,000, of whichapproximately ￡115,000 is distributed to its shareholders each year.The tax system in Palladia:– No taxes on income or capital profits.– 4% withholding tax on dividends paid to shareholders resident outside Palladia.Required:(a) Prepare detailed explanatory notes, including relevant supporting calculations, on the effect of the followingissues on the amount of corporation tax payable by Nikau Ltd for the year ending 31 March 2008.(i) The costs of developing ‘Project Sabal’ and the significant commercial changes to the company’sactivities arising out of its implementation. (8 marks)
3 Palm plc recently acquired 100% of the ordinary share capital of Nikau Ltd from Facet Ltd. Palm plc intends to use
Nikau Ltd to develop a new product range, under the name ‘Project Sabal’. Nikau Ltd owns shares in a non-UK
resident company, Date Inc.
The following information has been extracted from client files and from a meeting with the Finance Director of Palm
plc.
Palm plc:
– Has more than 40 wholly owned subsidiaries such that all group companies pay corporation tax at 30%.
– All group companies prepare accounts to 31 March.
– Acquired Nikau Ltd on 1 November 2007 from Facet Ltd, an unrelated company.
Nikau Ltd:
– UK resident company that manufactures domestic electronic appliances for sale in the European Union (EU).
– Large enterprise for the purposes of the enhanced relief available for research and development expenditure.
– Trading losses brought forward as at 1 April 2007 of ￡195,700.
– Budgeted taxable trading profit of ￡360,000 for the year ending 31 March 2008 before taking account of ‘Project
Sabal’.
– Dividend income of ￡38,200 will be received in the year ending 31 March 2008 in respect of the shares in Date
Inc.
‘Project Sabal’:
– Development of a range of electronic appliances, for sale in North America.
– Project Sabal will represent a significant advance in the technology of domestic appliances.
– Nikau Ltd will spend ￡70,000 on staffing costs and consumables researching and developing the necessary
technology between now and 31 March 2008. Further costs will be incurred in the following year.
– Sales to North America will commence in 2009 and are expected to generate significant profits from that year.
Shares in Date Inc:
– Nikau Ltd owns 35% of the ordinary share capital of Date Inc.
– The shares were purchased from Facet Ltd on 1 June 2003 for their market value of ￡338,000.
– The sale was a no gain, no loss transfer for the purposes of corporation tax.
– Facet Ltd purchased the shares in Date Inc on 1 March 1994 for ￡137,000.
Date Inc:
– A controlled foreign company resident in the country of Palladia.
– Annual chargeable profits arising out of property investment activities are approximately ￡120,000, of which
approximately ￡115,000 is distributed to its shareholders each year.
The tax system in Palladia:
– No taxes on income or capital profits.
– 4% withholding tax on dividends paid to shareholders resident outside Palladia.
Required:
(a) Prepare detailed explanatory notes, including relevant supporting calculations, on the effect of the following
issues on the amount of corporation tax payable by Nikau Ltd for the year ending 31 March 2008.
(i) The costs of developing ‘Project Sabal’ and the significant commercial changes to the company’s
activities arising out of its implementation. (8 marks)
相关考题：
(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)
In January 2008 Arti entered in a contractual agreement with Bee Ltd to write a study manual for an international accountancy body’s award. The manual was to cover the period from September 2008 till June 2009, and it was a term of the contract that the text be supplied by 30 June 2008 so that it could be printed in time for September. By 30 May, Arti had not yet started on the text and indeed he had written to Bee Ltd stating that he was too busy to write the text.Bee Ltd was extremely perturbed by the news, especially as it had acquired the contract to supply all of theaccountancy body’s study manuals and had already incurred extensive preliminary expenses in relation to the publication of the new manual.Required:In the context of the law of contract, advise Bee Ltd whether they can take any action against Arti.(10 marks)
3 (a) Leigh, a public limited company, purchased the whole of the share capital of Hash, a limited company, on 1 June2006. The whole of the share capital of Hash was formerly owned by the five directors of Hash and under theterms of the purchase agreement, the five directors were to receive a total of three million ordinary shares of $1of Leigh on 1 June 2006 (market value $6 million) and a further 5,000 shares per director on 31 May 2007,if they were still employed by Leigh on that date. All of the directors were still employed by Leigh at 31 May2007.Leigh granted and issued fully paid shares to its own employees on 31 May 2007. Normally share options issuedto employees would vest over a three year period, but these shares were given as a bonus because of thecompany’s exceptional performance over the period. The shares in Leigh had a market value of $3 million(one million ordinary shares of $1 at $3 per share) on 31 May 2007 and an average fair value of$2·5 million (one million ordinary shares of $1 at $2·50 per share) for the year ended 31 May 2007. It isexpected that Leigh’s share price will rise to $6 per share over the next three years. (10 marks)Required:Discuss with suitable computations how the above share based transactions should be accounted for in thefinancial statements of Leigh for the year ended 31 May 2007.
(ii) Comment briefly on the use of its own tree plantations as a source of raw materials by Our Timbers Ltd.(3 marks)
(b) Advise the management of SCC Ltd of THREE strategies that should be considered in order to improve thefuture performance of SCC Ltd. (6 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)
6 Assume today’s date is 16 April 2005.Henry, aged 48, is the managing director of Happy Home Ltd, an unquoted UK company specialising in interiordesign. He is wealthy in his own right and is married to Helen, who is 45 years old. They have two children – Stephen,who is 19, and Sally who is 17.As part of his salary, Henry was given 3,000 shares in Happy Home Ltd with an option to acquire a further 10,000shares. The options were granted on 15 July 2003, shortly after the company started trading, and were not part ofan approved share option scheme. The free shares were given to Henry on the same day.The exercise price of the share options was set at the then market value of ￡1·00 per share. The options are notcapable of being exercised after 10 years from the date of grant. The company has been successful, and the currentvalue of the shares is now ￡14·00 per share. Another shareholder has offered to buy the shares at their market value,so Henry exercised his share options on 14 April 2005 and will sell the shares next week, on 20 April 2005.With the company growing in size, Henry wishes to recruit high quality staff, but the company lacks the funds to paythem in cash. Henry believes that giving new employees the chance to buy shares in the company would help recruitstaff, as they could share in the growth in value of Happy Home Ltd. Henry has heard that there is a particular sharescheme that is suitable for small, fast growing companies. He would like to obtain further information on how sucha scheme would work.Henry has accumulated substantial assets over the years. The family house is owned jointly with Helen, and is worth￡650,000. Henry has a ￡250,000 mortgage on the house. In addition, Henry has liquid assets worth ￡340,000and Helen has shares in quoted companies currently worth ￡125,000. Henry has no forms of insurance, and believeshe should make sure that his wealth and family are protected. He is keen to find out what options he should beconsidering.Required:(a) (i) State how the gift of the 3,000 shares in Happy Home Ltd was taxed. (1 mark)
(b) Identify the most appropriate approved share option scheme for Happy Home Ltd. Outline the schemerequirements and the tax benefits of using it compared to the current unapproved scheme. (6 marks)
(ii) Briefly outline the tax consequences for Henry if the types of protection identified in (i) were to beprovided for him by Happy Home Ltd compared to providing them for himself. You are not required todiscuss the corporation tax (CT) consequences for Happy Home Ltd. (4 marks)
2 Benny Korere has been employed as the sales director of Golden Tan plc since 1994. He earns an annual salary of￡32,000 and is provided with a petrol-driven company car which has a CO2 emission rate of 187g/km and had alist price when new of ￡22,360. In August 2003, when he was first provided with the car, Benny paid the company￡6,100 towards the capital cost of the car. Golden Tan plc does not pay for any of Benny’s private petrol and he isalso required to pay his employer ￡18 per month as a condition of being able to use the car for private purposes.On 1 December 2006 Golden Tan plc notified Benny that he would be made redundant on 28 February 2007. Onthat day the company will pay him his final month’s salary together with a payment of ￡8,000 in lieu of the threeremaining months of his six-month notice period in accordance with his employment contract. In addition thecompany will pay him ￡17,500 in return for agreeing not to work for any of its competitors for the six-month periodending 31 August 2007.On receiving notification of his redundancy, Benny immediately contacted Joe Egmont, the managing director ofSummer Glow plc, who offered him a senior management position leading the company’s expansion into EasternEurope. Summer Glow plc is one of Golden Tan plc’s competitors and one of the most innovative companies in theindustry, although not all of its strategies have been successful.Benny has agreed to join Summer Glow plc on 1 September 2007 for an annual salary of ￡39,000. On the day hejoins the company, Summer Glow plc will grant him an option to purchase 10,000 ordinary shares in the companyfor ￡2·20 per share under an unapproved share option scheme. Benny can exercise the option once he has beenemployed for six months but must hold the shares for at least a year before he sells them.The new job will require Benny to spend a considerable amount of time in London. Summer Glow plc has offeredBenny the exclusive use of a flat that the company purchased on 1 June 2003 for ￡165,000; the flat is currentlyrented out. The flat will be made available from 1 September 2007. The company will pay all of the utility billsrelating to the flat as well as furnishing and maintaining it. Summer Glow plc has also suggested that if Benny wouldrather live in a more central part of the city, the company could sell the existing flat and buy a more centrally locatedone, of the same value, with the proceeds.On 15 March 2007 Benny intends to sell 5,800 shares in Mahana plc, a quoted company, for ￡24,608. Histransactions in the company’s shares have been as follows:￡June 1988 Purchased 8,400 shares 6,744February 1996 Sale of rights nil paid 610January 2005 Purchased 1,300 shares 2,281The sale of rights, nil paid, was not treated as a part disposal of Benny’s holding in Mahana plc.Benny’s shareholding in Mahana plc represents less than 1% of the company’s issued ordinary share capital. He willnot make any other capital disposals in 2006/07.In addition to his employment income, Benny receives rental income of ￡4,000 (net of deductible expenses) eachyear. He normally submits his tax return in August but he has not yet prepared his return for 2005/06. He expectsto be very busy in December and January and is planning to prepare his tax return in late February 2007.Required:(a) Calculate Benny’s employment income for 2006/07. (4 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)
(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)
5 (a) Carver Ltd was incorporated and began trading in August 2002. It is a close company with no associatedcompanies. It has always prepared accounts to 31 December and will continue to do so in the future.It has been decided that Carver Ltd will sell its business as a going concern to Blade Ltd, an unconnectedcompany, on 31 July 2007. Its premises and goodwill will be sold for ￡2,135,000 and ￡290,000 respectivelyand its machinery and equipment for ￡187,000. The premises, which do not constitute an industrial building,were acquired on 1 August 2002 for ￡1,808,000 and the goodwill has been generated internally by thecompany. The machinery and equipment cost ￡294,000; no one item will be sold for more than its original cost.The tax adjusted trading profit of Carver Ltd in 2007, before taking account of both capital allowances and thesale of the business assets, is expected to be ￡81,000. The balance on the plant and machinery pool for thepurposes of capital allowances as at 31 December 2006 was ￡231,500. Machinery costing ￡38,000 waspurchased on 1 March 2007. Carver Ltd is classified as a small company for the purposes of capital allowances.On 1 August 2007, the proceeds from the sale of the business will be invested in either an office building or aportfolio of UK quoted company shares, as follows:Office buildingThe office building would be acquired for ￡3,100,000; the vendor is not registered for value added tax (VAT).Carver Ltd would borrow the additional funds required from a UK bank. The building is let to a number ofcommercial tenants who are not connected with Carver Ltd and will pay rent, in total, of ￡54,000 per calendarquarter, in advance, commencing on 1 August 2007. The company’s expenditure for the period from 1 August2007 to 31 December 2007 is expected to be:￡Loan interest payable to UK bank 16,000Building maintenance costs 7,500Share portfolioShares would be purchased for the amount of the proceeds from the sale of the business with no need for furtherloan finance. It is estimated that the share portfolio would generate dividends of ￡36,000 and capital gains, afterindexation allowance, of ￡10,000 in the period from 1 August 2007 to 31 December 2007.All figures are stated exclusive of value added tax (VAT).Required:(i) Taking account of the proposed sale of the business on 31 July 2007, state with reasons the date(s) onwhich Carver Ltd must submit its corporation tax return(s) for the year ending 31 December 2007.(2 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) Explain why making sales of Sabals in North America will have no effect on Nikau Ltd’s ability to recover itsinput tax. (3 marks)Notes: – you should assume that the corporation tax rates and allowances for the financial year to 31 March 2007will continue to apply for the foreseeable future.– you should ignore indexation allowance.
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)
3 Spica, one of the director shareholders of Acrux Ltd, has been in dispute with the other shareholders over plans toexpand the company’s activities overseas. In order to resolve the position it has been agreed that Spica will sell hershares back to the company. Once the purchase of her shares has taken place, the company intends to establish anumber of branches overseas and acquire a shareholding in a number of companies that are resident and trade inoverseas countries.The following information has been obtained from client files and meetings with the parties involved.Acrux Ltd:– An unquoted UK resident company.– Share capital consists of 50,000 ordinary shares issued at ￡1·90 per share in July 2000.– None of the other shareholders has any connection with Spica.The purchase of own shares:– The company will purchase all of Spica’s shares for ￡8 per share.– The transaction will take place by the end of 2008.Spica:– Purchased 8,000 shares in Acrux Ltd for ￡2 per share on 30 September 2003.– Has no income in the tax year 2008/09.– Has chargeable capital gains in the tax year 2008/09 of ￡3,800.– Has houses in the UK and the country of Solaris and divides her time between them.Investment in non-UK resident companies:– Acrux Ltd will acquire between 15% and 20% of each of the non-UK resident companies.– The companies will not be controlled foreign companies as the rates of tax in the overseas countries will bebetween 23% and 42%.– There may or may not be a double tax treaty between the UK and the overseas countries in which the companiesare resident. Where there is a treaty, it will be based on the OECD model treaty.– None of the countries concerned levy withholding tax on dividends paid to UK companies.– The directors of Acrux Ltd are concerned that the rate of tax suffered on the profits of the overseas companieswill be very high as they will be taxed in both the overseas country and in the UK.Required:(a) (i) Prepare detailed calculations to determine the most beneficial tax treatment of the payment Spica willreceive for her shares; (7 marks)
5 Gagarin wishes to persuade a number of wealthy individuals who are business contacts to invest in his company,Vostok Ltd. He also requires advice on the recoverability of input tax relating to the purchase of new premises.The following information has been obtained from a meeting with Gagarin.Vostok Ltd:– An unquoted UK resident company.– Gagarin owns 100% of the company’s ordinary share capital.– Has 18 employees.– Provides computer based services to commercial companies.– Requires additional funds to finance its expansion.Funds required by Vostok Ltd:– Vostok Ltd needs to raise ￡420,000.– Vostok Ltd will issue 20,000 shares at ￡21 per share on 31 August 2008.– The new shareholder(s) will own 40% of the company.– Part of the money raised will contribute towards the purchase of new premises for use by Vostok Ltd.Gagarin’s initial thoughts:– The minimum investment will be 5,000 shares and payment will be made in full on subscription.– Gagarin has a number of wealthy business contacts who may be interested in investing.– Gagarin has heard that it may be possible to obtain tax relief for up to 60% of the investment via the enterpriseinvestment scheme.Wealthy business contacts:– Are all UK resident higher rate taxpayers.– May wish to borrow the funds to invest in Vostok Ltd if there is a tax incentive to do so.New premises:– Will cost ￡446,500 including value added tax (VAT).– Will be used in connection with all aspects of Vostok Ltd’s business.– Will be sold for ￡600,000 plus VAT in six years time.– Vostok Ltd will waive the VAT exemption on the sale of the building.The VAT position of Vostok Ltd:– In the year ending 31 March 2009, 28% of Vostok Ltd’s supplies will be exempt for the purposes of VAT.– This percentage is expected to reduce over the next few years.– Irrecoverable input tax due to the company’s partially exempt status exceeds the de minimis limits.Required:(a) Prepare notes for Gagarin to use when speaking to potential investors. The notes should include:(i) The tax incentives immediately available in respect of the amount invested in shares issued inaccordance with the enterprise investment scheme; (5 marks)
1 Stuart is a self-employed business consultant aged 58. He is married to Rebecca, aged 55. They have one child,Sam, who is aged 24 and single.In November 2005 Stuart sold a house in Plymouth for ￡422,100. Stuart had inherited the house on the death ofhis mother on 1 May 1994 when it had a probate value of ￡185,000. The subsequent pattern of occupation was asfollows:1 May 1994 to 28 February 1995 occupied by Stuart and Rebecca as main residence1 March 1995 to 31 December 1998 unoccupied1 January 1999 to 31 March 2001 let out (unfurnished)1 April 2001 to 30 November 2001 occupied by Stuart and Rebecca1 December 2001 to 30 November 2005 used occasionally as second homeBoth Stuart and Rebecca had lived in London from March 1995 onwards. On 1 March 2001 Stuart and Rebeccabought a house in London in their joint names. On 1 January 2002 they elected for their London house to be theirprincipal private residence with effect from that date, up until that point the Plymouth property had been their principalprivate residence.No other capital disposals were made by Stuart in the tax year 2005/06. He has ￡29,500 of capital losses broughtforward from previous years.Stuart intends to invest the gross sale proceeds from the sale of the Plymouth house, and is considering twoinvestment options, both of which he believes will provide equal risk and returns. These are as follows:(1) acquiring shares in Omikron plc; or(2) acquiring further shares in Omega plc.Notes:1. Omikron plc is a listed UK trading company, with 50,250,000 shares in issue. Its shares currently trade at 42pper share.2. Stuart and Rebecca helped start up the company, which was then Omega Ltd. The company was formed on1 June 1990, when they each bought 24,000 shares for ￡1 per share. The company became listed on 1 May1997. On this date their holding was subdivided, with each of them receiving 100 shares in Omega plc for eachshare held in Omega Ltd. The issued share capital of Omega plc is currently 10,000,000 shares. The share priceis quoted at 208p – 216p with marked bargains at 207p, 211p, and 215p.Stuart and Rebecca’s assets (following the sale of the Plymouth house but before any investment of the proceeds) areas follows:Assets Stuart Rebecca￡ ￡Family house in London 450,000 450,000Cash from property sale 422,100 –Cash deposits 165,000 165,000Portfolio of quoted investments – 250,000Shares in Omega plc see above see aboveLife insurance policy note 1 note 1Note:1. The life insurance policy will pay out a sum of ￡200,000 on the death of the first spouse to die.Stuart has recently been diagnosed with a serious illness. He is expected to live for another two or three years only.He is concerned about the possible inheritance tax that will arise on his death. Both he and Rebecca have wills whoseterms transfer all assets to the surviving spouse. Rebecca is in good health.Neither Stuart nor Rebecca has made any previous chargeable lifetime transfers for the purposes of inheritance tax.Required:(a) Calculate the taxable capital gain on the sale of the Plymouth house in November 2005 (9 marks)
3 The Stiletto Partnership consisted of three partners, Clint, Ben and Amy, who shared the profits of the businessequally. On 28 February 2007 the partners sold the business to Razor Ltd, in exchange for shares in Razor Ltd, witheach former partner owning one third of the new company.The recent, tax adjusted, trading profits of the Stiletto Partnership have been as follows:￡Year ended 30 June 2006 92,1241 July 2006 to 28 February 2007 81,795Clint, who was 65 on 5 October 2006, retired when the business was sold to Razor Ltd. He is now suggesting thatif the sale of the partnership, and his retirement, had been delayed until 30 April 2007, his total tax liability wouldhave been reduced. Clint’s only other income is gross pension income of ￡6,100 per year, which he began receivingin the tax year 2005/06. Clint did not receive any salary or dividends from Razor Ltd. It is estimated that thepartnership’s tax adjusted trading profits for the period from 1 March 2007 to 30 April 2007 would have been￡20,760. Clint has overlap profits of ￡14,250 brought forward from when the partnership began trading.Razor Ltd manufactures industrial cutting tools. On 1 July 2007, Razor Ltd will subscribe for the whole of the ordinaryshare capital of Cutlass Inc, a company newly incorporated in the country of Sharpenia. It is intended that CutlassInc will purchase partly finished tools from Razor Ltd and customise them in Sharpenia. It is anticipated that CutlassInc’s annual profits chargeable to corporation tax will be approximately ￡120,000.Ben and Amy will be the directors of Cutlass Inc, although Ben will not be involved in the company’s business on aday-to-day basis. Amy intends to spend one or two weeks each month in the country of Sharpenia looking after thecompany’s affairs. The remainder of her time will be spent in the UK. Amy has employment contracts with both RazorLtd and Cutlass Inc and her duties for Cutlass Inc will be carried out wholly in Sharpenia. Cutlass Inc will pay forAmy’s flights to and from Sharpenia and for her husband and baby to visit her there twice a year. Amy is currentlyUK resident and ordinarily resident.The system of income tax and corporation tax in the country of Sharpenia is broadly similar to that in the UK althoughthe rate of corporation tax is 38% regardless of the level of profits. There is a double tax treaty between the UK andSharpenia based on the OECD model treaty. The clause in the treaty dealing with company residency states that acompany resident in both countries under domestic law will be regarded under the treaty as being resident only in thecountry where it is effectively managed and controlled. Sharpenia is not a member of the European Union.Required:(a) (i) Calculate Clint’s taxable trading profits for the tax years 2006/07 and 2007/08 for both of thealternative retirement dates (28 February 2007 and 30 April 2007). (3 marks)
YouaredesigninganActiveDirectoryimplementationstrategytopresenttoexecutivesfromyourcompanyandfromContoso,Ltd.Whichimplementationstrategyshouldyouuse?() A.UpgradetheNewYorkdomain.UpgradetheChicagodomain.CreateapristineforestforContoso,Ltd.B.Createapristineforest.UpgradetheNewYorkdomain.UpgradetheChicagodomain.Donothingfurther.C.Createpristineforest.UpgradetheNewYorkdomain.UpgradetheChicagodomain.CreateapristineforestforContoso,Ltd.D.Createapristineforest.UpgradetheNewYorkdomain.UpgradetheChicagodomain.CreateanewchilddomainforContoso,Ltd.
The sales representative from Correct Copies, Ltd. returned Mr. Yoshida's call while he was ___.A. through B. along C. out D. aside
You are designing an Active Directory implementation strategy to present to executives from your company and from Contoso， Ltd. Which implementation strategy should you use？（）A、 Upgrade the New York domain. Upgrade the Chicago domain. Create a pristine forest for Contoso， Ltd.B、 Create a pristine forest. Upgrade the New York domain. Upgrade the Chicago domain. Do nothing further.C、 Create pristine forest. Upgrade the New York domain.Upgrade the Chicago domain.Create a pristine forest for Contoso， Ltd.D、 Create a pristine forest.Upgrade the New York domain. Upgrade the Chicago domain.Create a new child domain for Contoso， Ltd.
You are designing an Active Directory implementation strategy to present to executives from your company and from Contoso, Ltd. Which implementation strategy should you use?（）A、Upgrade the New York domain. Upgrade the Chicago domain. Create a pristine forest for Contoso, Ltd.B、Create a pristine forest. Upgrade the New York domain. Upgrade the Chicago domain. Do nothing further.C、Create pristine forest. Upgrade the New York domain. Upgrade the Chicago domain. Create a pristine forest for Contoso, Ltd. D、Create a pristine forest. Upgrade the New York domain. Upgrade the Chicago domain. Create a new child domain for Contoso, Ltd.
单选题The author seems to suggest that _____.Athe attempt to grow the Judean palm date will end in failureBthe effort to reintroduce the Judean palm date is sure to pay offCthe researchers are likely to create a new species of the Judean palm dateDthe researchers stand a chance of success to renew the Judean palm date
单选题Your company named Contoso， Ltd. has a Web server named WEB1. The Web server runs Windows Server 2008. The fully qualified domain name of WEB1 is web1.contoso.com. The public DNS server has an alias record named owa.contoso.com that maps to web1.contoso.com. Users access WEB1 from the Internet by using http：//owa.contoso.com. The new company security policy states that the owa.contoso.com site must be available for Internet users only through secure HTTP （HTTPS） protocol. The security policy also states that users must not get security warnings when they connect to the site. You need to request a certificate from a public certification authority （CA）. Which Common Name should you use？（）AContoso， Ltd.Bowa.contoso.comCWEB1Dweb1.contoso.com
单选题You are designing an Active Directory implementation strategy to present to executives from your company and from Contoso， Ltd. Which implementation strategy should you use？（）A Upgrade the New York domain. Upgrade the Chicago domain. Create a pristine forest for Contoso， Ltd.B Create a pristine forest. Upgrade the New York domain. Upgrade the Chicago domain. Do nothing further.C Create pristine forest. Upgrade the New York domain.Upgrade the Chicago domain.Create a pristine forest for Contoso， Ltd.D Create a pristine forest.Upgrade the New York domain. Upgrade the Chicago domain.Create a new child domain for Contoso， Ltd.