(b) (i) Advise Alasdair of the tax implications and relative financial risks attached to the following property
investments:
(1) buy to let residential property;
(2) commercial property; and
(3) shares in a property investment company/unit trust. (9 marks)
第1题:
6 Alasdair, aged 42, is single. He is considering investing in property, as he has heard that this represents a good
investment. In order to raise the funds to buy the property, he wants to extract cash from his personal company, Beezer
Limited, whose year end is 31 December.
Beezer Limited was formed on 1 May 1998 with £1,000 of capital issued as 1,000 £1 ordinary shares, and traded
until 1 January 2005 when Alasdair sold the trade and related assets. The company’s only asset is cash of
£120,000. Alasdair wants to extract this cash from the company with the minimum amount of tax payable. He is
considering either, paying himself a dividend of £120,000, on 31 March 2006, after which the company would have
no assets and be wound up or, leaving the cash in the company and then liquidating the company. Costs of liquidation
of £5,000 would then be incurred.
Since Beezer Limited ceased trading, Alasdair has been taken on as a partner at a marketing firm, Gallus & Co. He
estimates his profit share for the year of assessment 2005/06 will be £30,000. He has not made any capital disposals
in the current tax year.
Alasdair wishes to reinvest the cash extracted from Beezer Limited in property but is not sure whether he should invest
directly in residential or commercial property, or do so via some form. of collective investment. He is aware that Gallus
& Co are looking to rent a new warehouse which could be bought for £200,000. Alasdair thinks that he may be able
to buy the warehouse himself and lease it to his firm, but only if he can borrow the additional money to buy the
property.
Alasdair has a 25% shareholding in another company, Glaikit Limited, whose year end is 31 March. The remaining
shares in this company are held by his friend, Gill. Alasdair is considering borrowing £15,000 from Glaikit Limited
on 1 January 2006. He does not intend to pay any interest on the loan, which is likely to be written off some time
in 2007. Alasdair does not have any connection with Glaikit Limited other than his shareholding.
Required:
(a) Advise Alasdair whether or not a dividend payment will result in a higher after-tax cash sum than the
liquidation of Beezer Limited. Assume that either the dividend would be paid on 31 March 2006 or the
liquidation would take place on 31 March 2006. (9 marks)
Assume that Beezer Limited has always paid corporation tax at or above the small companies rate of 19%
and that the tax rates and allowances for 2004/05 apply throughout this part.
第2题:
(ii) Explain the income tax (IT), national insurance (NIC) and capital gains tax (CGT) implications arising on
the grant to and exercise by an employee of an option to buy shares in an unapproved share option
scheme and on the subsequent sale of these shares. State clearly how these would apply in Henry’s
case. (8 marks)
第3题:
(ii) Compute the annual income tax saving from your recommendation in (i) above as compared with the
situation where Cindy retains both the property and the shares. Identify any other tax implications
arising from your recommendation. Your answer should consider all relevant taxes. (3 marks)
第4题:
6 Andrew is aged 38 and is single. He is employed as a consultant by Bestadvice & Co and pays income tax at the
higher rate.
Andrew is considering investing in a new business, and to provide funds for this investment he has recently disposed
of the following assets:
(1) A short leasehold interest in a residential property. Andrew originally paid £50,000 for a 47 year lease of the
property in May 1995, and assigned the lease in May 2006 for £90,000.
(2) His holding of £10,000 7% Government Stock, on which interest is payable half-yearly on 20 April and
20 October. Andrew originally purchased this holding on 1 June 1999 for £9,980 and he sold it for £11,250
on 14 March 2005.
Andrew intends to subscribe for ordinary shares in a new company, Scalar Limited, which will be a UK based
manufacturing company. Three investors (including Andrew) have been identified, but a fourth investor may also be
invited to subscribe for shares. The investors are all unconnected, and would subscribe for shares in equal measure.
The intention is to raise £450,000 in this manner. The company will also raise a further £50,000 from the investors
in the form. of loans. Andrew has been told that he can take advantage of some tax reliefs on his investment in Scalar
Limited, but does not know anything about the details of these reliefs
Andrew’s employer, Bestadvice & Co, is proposing to change the staff pension scheme from a defined benefit scheme
to which the firm and the employees each contribute 6% of their annual salary, to a defined contribution scheme, to
which the employees will continue to contribute 6%, but the firm will contribute 8% of their annual salary. The
majority of Andrew’s colleagues are opposed to this move, but, given the increase in the firm’s contribution rate
Andrew himself is less sure that the proposal is without merit.
Required:
(a) (i) Calculate the chargeable gain arising on the assignment of the residential property lease in May 2006.
(2 marks)
第5题:
2 Clifford and Amanda, currently aged 54 and 45 respectively, were married on 1 February 1998. Clifford is a higher
rate taxpayer who has realised taxable capital gains in 2007/08 in excess of his capital gains tax annual exemption.
Clifford moved into Amanda’s house in London on the day they were married. Clifford’s own house in Oxford, where
he had lived since acquiring it for £129,400 on 1 August 1996, has been empty since that date although he and
Amanda have used it when visiting friends. Clifford has been offered £284,950 for the Oxford house and has decided
that it is time to sell it. The house has a large garden such that Clifford is also considering an offer for the house and
a part only of the garden. He would then sell the remainder of the garden at a later date as a building plot. His total
sales proceeds will be higher if he sells the property in this way.
Amanda received the following income from quoted investments in 2006/07:
£
Dividends in respect of quoted trading company shares 1,395
Dividends paid by a Real Estate Investment Trust out of tax exempt property income 485
On 1 May 2006, Amanda was granted a 22 year lease of a commercial investment property. She paid the landlord
a premium of £6,900 and also pays rent of £2,100 per month. On 1 June 2006 Amanda granted a nine year
sub-lease of the property. She received a premium of £14,700 and receives rent of £2,100 per month.
On 1 September 2006 Amanda gave quoted shares with a value of £2,200 to a registered charity. She paid broker’s
fees of £115 in respect of the gift.
Amanda began working for Shearer plc, a quoted company, on 1 June 2006 having had a two year break from her
career. She earns an annual salary of £38,600 and was paid a bonus of £5,750 in August 2006 for agreeing to
come and work for the company. On 1 August 2006 Amanda was provided with a fully expensed company car,
including the provision of private petrol, which had a list price when new of £23,400 and a CO2 emissions rate of
187 grams per kilometre. Amanda is required to pay Shearer plc £22 per month in respect of the private use of the
car. In June and July 2006 Amanda used her own car whilst on company business. She drove 720 business miles
during this two month period and was paid 34 pence per mile. Amanda had PAYE of £6,785 deducted from her gross
salary in the tax year 2006/07.
After working for Shearer plc for a full year, Amanda becomes entitled to the following additional benefits:
– The opportunity to purchase a large number of shares in Shearer plc on 1 July 2007 for £3·30 per share. It is
anticipated that the share price on that day will be at least £7·50 per share. The company will make an interestfree
loan to Amanda equal to the cost of the shares to be repaid in two years.
– Exclusive free use of the company sailing boat for one week in August 2007. The sailing boat was purchased by
Shearer plc in January 2005 for use by its senior employees and costs the company £1,400 a week in respect
of its crew and other running expenses.
Required:
(a) (i) Calculate Clifford’s capital gains tax liability for the tax year 2007/08 on the assumption that the Oxford
house together with its entire garden is sold on 31 July 2007 for £284,950. Comment on the relevance
to your calculations of the size of the garden; (5 marks)
第6题:
(b) Explain the corporation tax and value added tax (VAT) implications of the following aspects of the proposed
restructuring of the Rapier Ltd group.
(i) The immediate tax implications of the restructuring. (6 marks)
第7题:
(b) (i) Explain, by reference to Coral’s residence, ordinary residence and domicile position, how the rental
income arising in respect of the property in the country of Kalania will be taxed in the UK in the tax year
2007/08. State the strategy that Coral should adopt in order to minimise the total income tax suffered
on the rental income. (7 marks)
第8题:
(b) You are the manager responsible for the audit of Poppy Co, a manufacturing company with a year ended
31 October 2008. In the last year, several investment properties have been purchased to utilise surplus funds
and to provide rental income. The properties have been revalued at the year end in accordance with IAS 40
Investment Property, they are recognised on the statement of financial position at a fair value of $8 million, and
the total assets of Poppy Co are $160 million at 31 October 2008. An external valuer has been used to provide
the fair value for each property.
Required:
(i) Recommend the enquiries to be made in respect of the external valuer, before placing any reliance on their
work, and explain the reason for the enquiries; (7 marks)
第9题:
Which of the following statements concerning intellectual property is wrong?()
第10题:
You have a custom button, with should have a Property "IsActive", one must be able to bind this Property on a class Property.()
第11题:
Intellectual property is an intangible creation
Intellectual property in ludes patents,trademarks,copyrights,etc.
Intellectual property is a visible creation
There are some agreement sconcerning intellectual property under the WTO
第12题:
Add a MessageBodyMember attribute to the CodeName property and set the ProtectionLevel to Sign. Add a MessageBodyMember attribute to the SecretHandshake property and set the ProtectionLevel to EncryptAndSign.
Add a DataProtectionPermission attribute to the each property and set the ProtectData property to true.
Add an xmlText attribute to the CodeName property and set the DataType property to Signed. Add a PasswordPropertyText attribute to the SecretHandshake property and set its value to true.
Add an ImmutableObject attribute to the CodeName property and set its value property to true. Add a Browsable attribute to the SecretHandshake property and set its value to false.
第13题:
(c) State the tax consequences for both Glaikit Limited and Alasdair if he borrows money from the company, as
proposed, on 1 January 2006. (3 marks)
第14题:
(b) (i) Advise Benny of the income tax implications of the grant and exercise of the share options in Summer
Glow plc on the assumption that the share price on 1 September 2007 and on the day he exercises the
options is £3·35 per share. Explain why the share option scheme is not free from risk by reference to
the rules of the scheme and the circumstances surrounding the company. (4 marks)
第15题:
(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. Bill
believes that the company would be better off without Ben as a voting shareholder, and wishes to buy Ben’s
shares. However, Bill does not have sufficient funds to buy the shares himself, and so is wondering if the
company 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 to
repurchase 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 any
conditions 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 allowances
for the tax year 2005/06 apply throughout this question.
(b) [Ben’s address] [Firm’s address]
Dear Ben [Date]
A company purchase of own shares can be subject to capital gains treatment if certain conditions are satisfied. However, one
of these conditions is that the shares in question must have been held for a minimum period of five years. As at 1 May 2010,
your shares in Flower Limited have only been held for four years and ten months. As a result, the capital gains treatment will
not apply.
In the absence of capital gains treatment, the position on a company repurchase of its own shares is that the payment will
be treated as an income distribution (i.e. a dividend) in the hands of the recipient. The distribution element is calculated as
the proceeds received for the shares less the price paid for them. On the basis that the purchase price is £500,000, then the
element of distribution will be £499,500 (500,000 – 500). This would be taxed as follows:
第16题:
(ii) Advise Andrew of the tax implications arising from the disposal of the 7% Government Stock, clearly
identifying the tax year in which any liability will arise and how it will be paid. (3 marks)
第17题:
(ii) Advise Mr Fencer of the income tax implications of the proposed financing arrangements. (2 marks)
第18题:
(b) Advise Sergio on the appropriateness of investing in a domestic rental property in view of his personal
circumstances and recommend suitable alternative investments giving reasons for your advice. (4 marks)
第19题:
(b) You are an audit manager with specific responsibility for reviewing other information in documents containing
audited financial statements before your firm’s auditor’s report is signed. The financial statements of Hegas, a
privately-owned civil engineering company, show total assets of $120 million, revenue of $261 million, and profit
before tax of $9·2 million for the year ended 31 March 2005. Your review of the Annual Report has revealed
the following:
(i) The statement of changes in equity includes $4·5 million under a separate heading of ‘miscellaneous item’
which is described as ‘other difference not recognized in income’. There is no further reference to this
amount or ‘other difference’ elsewhere in the financial statements. However, the Management Report, which
is required by statute, is not audited. It discloses that ‘changes in shareholders’ equity not recognized in
income includes $4·5 million arising on the revaluation of investment properties’.
The notes to the financial statements state that the company has implemented IAS 40 ‘Investment Property’
for the first time in the year to 31 March 2005 and also that ‘the adoption of this standard did not have a
significant impact on Hegas’s financial position or its results of operations during 2005’.
(ii) The chairman’s statement asserts ‘Hegas has now achieved a position as one of the world’s largest
generators of hydro-electricity, with a dedicated commitment to accountable ethical professionalism’. Audit
working papers show that 14% of revenue was derived from hydro-electricity (2004: 12%). Publicly
available information shows that there are seven international suppliers of hydro-electricity in Africa alone,
which are all at least three times the size of Hegas in terms of both annual turnover and population supplied.
Required:
Identify and comment on the implications of the above matters for the auditor’s report on the financial
statements of Hegas for the year ended 31 March 2005. (10 marks)
第20题:
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)
(a) James – Inheritance tax arising on death
Lifetime transfers within seven years of death
The personal representatives of James’ estate will be responsible for paying the inheritance tax of £348,000.
Working – Available nil rate band
(b) Skipping a generation avoids a further charge to inheritance tax when the children die. Gifts will then only be taxed once before being inherited by the grandchildren, rather than twice.
(c) (1) Even if the donor does not survive for seven years, taper relief will reduce the amount of IHT payable after three years.
(2) The value of potentially exempt transfers and chargeable lifetime transfers are fixed at the time they are made.
(3) James therefore saved inheritance tax of £20,000 ((310,000 – 260,000) at 40%) by making the lifetime gift of property.
第21题:
transition-property属性语法格式正确的是()。
第22题:
You are creating a Windows Communication Foundation (WCF) service that accepts messages from clients when they are started. The message is defined as follows. [MessageContract] public class Agent { public string CodeName { get; set; }public string SecretHandshake { get; set; } } You have the following requirements: "The CodeName property must be sent in clear text. The service must be able to verify that the property value was not changed after being sent by the client. "The SecretHandshake property must not be sent in clear text and must be readable by the service. What should you do?()
第23题:
Add a MessageBodyMember attribute to the CodeName property and set the ProtectionLevel to Sign. Add a MessageBodyMember attribute to the SecretHandshake property and set the protectionLevel to EncryptAndSign.
Add a DataProtectionPermission attribute to the each property and set the ProtectData property to true.
Add an XmlText attribute to the CodeName property and set the DataType property to Signed. add a PasswordPropertyText attribute to the SecretHandshake property and set its value to true.
Add an ImmutableObject attribute to the CodeName property and set its value property to true. Add a Browsable attribute to the SecretHandshake property and set its value to false.