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(b) Advise on the capital gains implications should Trent Limited’s old building be sold as proposed. Support your
advice with relevant calculations. (4 marks)
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The writer mentioned the case of the United States to justify the policy of _______ .A providing financial support overseasB preventing foreign capital's controlC building industrial infrastructureD accepting foreign investment
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(ii) Discuss whether gains and losses that have been reported initially in one section of the performancestatement should be ‘recycled’ in a later period in another section and whether only ‘realised’ gains andlosses should be included in such a statement. (9 marks)
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(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)
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(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)
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(c) (i) Explain the capital gains tax (CGT) implications of a takeover where the consideration is in the form. ofshares (a ‘paper for paper’ transaction) stating any conditions that need to be satisfied. (4 marks)
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(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.
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(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)
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(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)
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(b) Explain by reference to Hira Ltd’s loss position why it may be beneficial for it not to claim any capitalallowances for the year ending 31 March 2007. Support your explanation with relevant calculations.(6 marks)
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(c) (i) Compute Gloria’s capital gains tax liability for 2006/07 ignoring any claims or elections available toreduce the liability. (3 marks)
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(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.
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(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)
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3 Damian is the finance director of Linden Limited, a medium sized, unquoted, UK trading company, with a 31 Julyyear end. Damian personally owns 10% of the ordinary issued share capital of Linden Limited, for which he paid￡10,000 in June 1998. He estimates that the current market value of Linden Limited is ￡9 million and that thecompany will make taxable profits of ￡1·4 million in the forthcoming year to 31 July 2007.(a) Damian believes that Linden Limited should conduct its activities in a socially responsible manner and to thisend has proposed that in future all cars purchased by the company should be low emission vehicles. The salesdirector has stated that several of his staff, who are the main recipients of company cars, other than the directors,are extremely unhappy with this proposal, perceiving it as downgrading their value and status.The cars currently provided to the sales staff have a list price of ￡19,600, on which Linden Limited receives abulk purchase discount of 6% from the dealer, and a CO2 emission rate of 168 grams/kilometre. The companypays for up to ￡400 of accessories, of the salesmen’s own choice to be fitted to the cars and all of the runningcosts, including private petrol. The cars are replaced every three years and the ‘old’ cars are sold at auction,because they are high mileage vehicles.The low emission cars it is proposed to purchase will have the same list price as the current cars, but the dealeris only prepared to offer a bulk discount of 5% on these vehicles. Damian does not propose to make any otherchanges to Linden Limited’s company car policy or practice.Required:(i) Explain the tax consequences of the proposed move to low emission vehicles for both the individualsalesmen and Linden Limited, illustrating your answer by means of relevant calculations of the tax andnational insurance (NIC) savings arising. (9 marks)
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(b) Peter, one of Linden Limited’s non-executive directors, having lived and worked in the UK for most of his adultlife, sold his home near London on 22 March 2006 and, together with his wife (a French citizen), moved to livein a villa which she owns in the south of France. Peter is now demanding that the tax deducted from his director’sfees, for the board meetings held on 18 April and 16 May 2006, be refunded, on the grounds that, as he is nolonger resident in the UK, he is no longer liable to UK income tax. All of the company’s board meetings are heldat its offices in Cambridge.Despite Peter’s assurance that none of the other companies of which he is a director has disputed his change oftax status, Damian is uncertain whether he should make the refunds requested. However, as Peter is a friend ofthe company’s founder, Linden Limited’s managing director is urging him to do so, stating that if the tax doeshave to be paid, then Linden Limited could always bear the cost.Required:Advise Damian whether Peter is correct in his assertion regarding his tax position and in the case that thereis a UK tax liability the implications of the managing director’s suggestion. You are not required to considernational insurance (NIC) issues. (4 marks)
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(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)
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(iii) Explain the potential corporation tax (CT) implications of Tay Limited transferring work to Trent Limited,and suggest how these can be minimised or eliminated. (3 marks)
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(d) Advise Trent Limited of the consequences arising from the submission of the incorrect value added tax (VAT)return, assuming that the company has previously had a good compliance record with regard to accountingfor VAT. (6 marks)
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(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)
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(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)
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(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)
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(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)
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(ii) Advise Mr Fencer of the income tax implications of the proposed financing arrangements. (2 marks)
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(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.
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(b) Prepare a reasoned explanation of how any capital gains tax arising in the UK on the sale of the paintingscan be minimised. (2 marks)
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(c) State the specific inquiries you should make of Robson Construction Co’s management relevant to itsaccounting for construction contracts. (6 marks)
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(c) (i) Calculate Benny’s capital gains tax liability for 2006/07. (6 marks)
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