问答题 2.

问答题 (a) Inheritance tax legislation does not actually contain a definition of who is, and who is not, a chargeable person. Required: (i) Explain whether or not a married couple is treated as a chargeable person for inheritance tax purposes.(1 mark) (ii) State the special inheritance tax measures which are applicable to married couples. (2 marks)

问答题 (b) Marcus died on 10 March 2015. He had made the following gifts during his lifetime: (1) On 14 January 2006, Marcus made a chargeable lifetime transfer of ￡290,000 to a trust. The trustees paid the lifetime inheritance tax of ￡3,000 which arose in respect of this gift. (2) On 3 February 2012, Marcus made a chargeable lifetime transfer of ￡420,000 to another trust. In addition to the gift, Marcus paid the related lifetime inheritance tax of ￡96,250 on this gift. (3) On 17 March 2012, Marcus made a gift (a potentially exempt transfer) of 30,000 ￡1 ordinary shares in Scarum Ltd, an unquoted investment company, to his daughter. Before the transfer, Marcus owned all of Scarum Ltd’s issued share capital of 100,000 ￡1 ordinary shares.On 17 March 2012, Scarum Ltd’s shares were worth ￡5 each for a holding of 30%, ￡9 each for a holding of 70%, and ￡12 each for a holding of 100%. The nil rate band for the tax year 2005–06 is ￡275,000, and for the tax year 2011–12 it is ￡325,000.Under the terms of his will, Marcus left his entire estate to his wife. Required: Calculate the inheritance tax which will be payable as a result of Marcus’s death. Note: You should ignore the inheritance tax annual exemption. (7 marks)