(ii) Assuming the new structure is implemented with effect from 1 August 2006, calculate the level ofmanagement charge that should be made by Bold plc to Linden Limited for the year ended 31 July2007, so as to minimise the group’s overall corporation tax

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(ii) Assuming the new structure is implemented with effect from 1 August 2006, calculate the level of

management charge that should be made by Bold plc to Linden Limited for the year ended 31 July

2007, so as to minimise the group’s overall corporation tax (CT) liability for that year. (2 marks)

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第1题

(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)

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第2题

4 (a) For this part, assume today’s date is 1 March 2006.Bill and Ben each own 50% of the ordinary share capital in Flower Limited, an unquoted UK trading companythat makes electronic toys. Flower Limited was incorporated on 1 August 2005 with 1,000 ￡1 ordinary shares,and commenced trading on the same day. The business has been successful, and the company has accumulateda large cash balance of ￡180,000, which is to be used to purchase a new factory. However, Bill and Ben havereceived an offer from a rival company, which they are considering. The offer provides Bill and Ben with twoalternative methods of payment for the purchase of their shares:(i) ￡480,000 for the company, inclusive of the ￡180,000 cash balance.(ii) ￡300,000 for the company assuming the cash available for the factory purchase is extracted prior to sale.Bill and Ben each currently receive a gross salary of ￡3,750 per month from Flower Limited. Part of the offerterms is that Bill and Ben would be retained as employees of the company on the same salary.Neither Bill nor Ben has used any of their capital gains tax annual exemption for the tax year 2005/06.Required:(i) Calculate which of the following means of extracting the ￡180,000 from Flower Limited on 31 March2006 will result in the highest after tax cash amount for Bill and Ben:(1) payment of a dividend, or(2) payment of a salary bonus.You are not required to consider the corporation tax (CT) implications for Flower Limited in youranswer. (5 marks)

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第3题

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)

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第4题

2 Clifford and Amanda, currently aged 54 and 45 respectively, were married on 1 February 1998. Clifford is a higherrate 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, wherehe had lived since acquiring it for ￡129,400 on 1 August 1996, has been empty since that date although he andAmanda have used it when visiting friends. Clifford has been offered ￡284,950 for the Oxford house and has decidedthat it is time to sell it. The house has a large garden such that Clifford is also considering an offer for the house anda part only of the garden. He would then sell the remainder of the garden at a later date as a building plot. His totalsales 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 1,395Dividends paid by a Real Estate Investment Trust out of tax exempt property income 485On 1 May 2006, Amanda was granted a 22 year lease of a commercial investment property. She paid the landlorda premium of ￡6,900 and also pays rent of ￡2,100 per month. On 1 June 2006 Amanda granted a nine yearsub-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’sfees 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 hercareer. She earns an annual salary of ￡38,600 and was paid a bonus of ￡5,750 in August 2006 for agreeing tocome 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 of187 grams per kilometre. Amanda is required to pay Shearer plc ￡22 per month in respect of the private use of thecar. In June and July 2006 Amanda used her own car whilst on company business. She drove 720 business milesduring this two month period and was paid 34 pence per mile. Amanda had PAYE of ￡6,785 deducted from her grosssalary 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 isanticipated that the share price on that day will be at least ￡7·50 per share. The company will make an interestfreeloan 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 byShearer plc in January 2005 for use by its senior employees and costs the company ￡1,400 a week in respectof 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 Oxfordhouse together with its entire garden is sold on 31 July 2007 for ￡284,950. Comment on the relevanceto your calculations of the size of the garden; (5 marks)

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第5题

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)

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第6题

1.publicclassSimpleCalc{2.publicintvalue；3.publicvoidcalculate（）{value+=7；}4.}And：1.publicclassMultiCalcextendsSimpleCalc{2.publicvoidcalculate（）{value-=3；}3.publicvoidcalculate（intmultiplier）{4.calculate（）；5.super.calculate（）；6.value*=multiplier；7.}8.publicstaticvoidmain（String[]args）{9.MultiCalccalculator=newMultiCalc（）；10.calculator.calculate（2）；11.System.out.println（”Valueis：+calculator.value）；12.}13.}Whatistheresult？（）

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第7题

目前我国银行间现券交易的结算日有（）。I.T+0 II.T+1 III.T+2 IV.T+3 A、I.II B、I.IV C、II.III D、III.IV

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(ii) Assuming the new structure is implemented with effect from 1 August 2006, calculate t

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