问答题Capstan requires advice on the transfer of a property to a trust, the sale of shares in respect of which relief has been received under the Enterprise Investment Scheme (EIS), and the sale of shares and qualifying corporate bonds following a takeover. The following information was obtained from a meeting with Capstan. Capstan: - Expects to have taxable income in the tax year 2012/13 of ￡80,000. - Transferred a UK property to a discretionary trust on 1 May 2012. - Plans to sell ordinary shares in Agraffe Ltd and loan stock and ordinary shares in Pinblock plc. - Will make all available claims to reduce the tax due in respect of his planned disposals. - Entrepreneurs' relief is not available in respect of any of these disposals. Transfer of a UK property to a discretionary trust: - Capstan acquired the property in May 2004 for ￡285,000. - The market value of the property on 1 May 2012 was ￡425,000. - Capstan had used the property as a second home throughout his period of ownership. - Capstan will pay any inheritance tax due on the gift of the property to the trust. Sale of ordinary shares in Agraffe Ltd: - Capstan subscribed for 18,000 shares in Agraffe Ltd for ￡32,000 on 1 February 2010. - He obtained EIS relief of ￡6,400 against his income tax liability. - Capstan intends to sell all of the shares for ￡20,000 on 1 July 2012. - Capstan will relieve the loss arising on the shares in the most tax efficient manner. Sale of loan stock and ordinary shares in Pinblock plc: - Capstan will sell ￡8,000 7% Pinblock plc non-convertible loan stock for ￡10,600. - Capstan will also sell 12,000 shares in Pinblock plc for ￡69,000. - The sales will take place on 1 August 2012. Capstan's acquisition of loan stock and ordinary shares in Pinblock plc: - Capstan purchased 15,000 shares in Wippen plc for ￡26,000 on 1 May 2005. - Pinblock plc acquired 100% of the ordinary share capital of Wippen plc on 1 October 2008. - The takeover was for bona fide commercial reasons and was not for the avoidance of tax. - Capstan received ￡8,000 Pinblock plc non-convertible loan stock (a qualifying corporate bond) and 20,000 ordinary shares in Pinblock plc in exchange for his shares in Wippen plc. - The loan stock and the shares were worth ￡9,000 and ￡40,000 respectively as at 1 October 2008. Required: (a) Set out, together with supporting calculations, the inheritance tax and capital gains tax implications of the transfer of the UK property to the trust and the date(s) on which any tax due will be payable. (b) Explain, with supporting calculations, in connection with the sale of shares in Agraffe Ltd - the tax implications of selling them on 1 July 2012; and - any advantages and disadvantages to Capstan of delaying the sale. (c) Calculate Capstan's taxable capital gains for the tax year 2012/13. Note: in parts (a) and (b) you should clearly state any assumptions you have made together with any additional information that you would need to confirm with Capstan before finalising your calculations. You should assume that the tax rates and allowances of the tax year 2011/12 will continue to apply for the foreseeable future.

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