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问答题Coral is the owner and managing director of Reef Ltd. She is considering the manner in which she will make her first pension contributions. In November 2012 she inherited her mother's house in the country of Kaiania, which is outside the European Economic Area (EEA). The following information has been extracted from client files and from telephone conversations with Coral. Coral: · 1975 - Born in the country of Kalania. Her father, who died in 2006, was domiciled in Kalania. · 2004 - Moved to the UK and has lived and worked here since then. · 2005 - Subscribed for 100% of the ordinary share capital of Reef Ltd. · Intends to sell Reef Ltd and return to live in the country of Kalania in 2017. · No income apart from that received from Reef Ltd. Reef Ltd: · AUK resident company with annual taxable total profits of approximately ￡350,000. · Fourteen employees including Coral. · Provides scuba diving lessons to members of the public and specialist underwater photography facilities for commercial organisations. Payments from Reef Ltd to Coral in 2012/13: · Director's fees of ￡460 per month. · Dividends paid of ￡16,250 in June 2012 and ￡16,250 in September 2012. Pension contributions: · Coral has not so far made any pension contributions in the tax year 2012/13 but wishes to make gross pension contributions of ￡9,000. · The contributions are to be made by Reef Ltd or Coral or a combination of the two in such a way as to minimise the total after tax cost. · Any contributions made by Coral will be funded by an additional dividend from Reef Ltd. · Coral was not a member of a pension scheme in 2011/12 or any previous years. House in the country of Kalania: · Beachfront property with potential rental income of ￡550 per month after deduction of allowable expenditure. · Coral will use it for holidays for two months each year. The tax system in the country of Kalania: · No capital gains tax or inheritance tax. · Income tax at 8% on income arising in the country of Kalania. · No double tax treaty with the UK. Required (a) With the objective of minimising the total after tax cost, advise Coral as to whether the gross pension contributions of ￡9,000 should be made: · wholly by Reef Ltd; or · by Coral to the extent that they are tax allowable with the balance made by Reef Ltd. Your answer should include supporting calculations where necessary. (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 2012/13. State the strategy that Coral should adopt in order to minimise the total income tax suffered on the rental income. (ii) Explain how the inclusion of rental income in Coral's UK income tax computation could affect the income tax due on her dividend income. You are not required to prepare calculations for part (b) of this question. Note: you should assume that the tax rates and allowances for the tax year 2011/12 and for the Financial Year to 31 March 2012 will continue to apply for the foreseeable future.

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问答题3.NocturneLtd,apartiallyexemptcompanyforthepurposesofvalueaddedtax(VAT),requiresadviceonthecorporationtaximplicationsofprovidinganassettooneofitsshareholders;theincometaximplicationsforanothershareholderofmakingaloantothecompany;andsimplifyingthewayinwhichitaccountsforVAT.NocturneLtd:–IsaUKresidenttradingcompany.–Preparesaccountsto31Marchannuallyandexpectstopaycorporationtaxattherateof20%.–Hasfourshareholders,eachofwhomowns25%ofthecompany’sordinarysharecapital.–Ownsalaptopcomputer,whichitpurchasedinOctober2012for￡1,200,andwhichhasacurrentmarketvalueof￡150.–Haspurchasednootherplantandmachineryforseveralyearsandthetaxwrittendownvalueofitsmainpoolat31March2015was￡nil.ProvisionofalaptopcomputertooneofNocturneLtd’sshareholders:–NocturneLtdisconsideringtwoalternativewaysofprovidingalaptopcomputerintheyearending31March2016forthepersonaluseofoneofitsshareholders,Jed.–JedisneitheradirectornoranemployeeofNocturneLtd.–Option1:NocturneLtdwillbuyanewlaptopcomputerfor￡1,800andgiveitimmediatelytoJed.–Option2:NocturneLtdwillgiftitsexistinglaptoptoJedandwillpurchaseareplacementforuseinthecompanyfor￡1,800.LoanfromSiglio:–Sigliowillloan￡60,000toNocturneLtdon1October2015tofacilitatethepurchaseofnewequipment.–SiglioisbothashareholderofNocturneLtdandthecompany’smanagingdirector.–NocturneLtdwillpayinterestatacommercialrateontheloanfromSiglio.–Sigliowillborrowthefullamountoftheloanfromhisbankonnormalcommercialterms.VAT–partialexemption:–NocturneLtdispartiallyexemptforthepurposesofVAT.–NocturneLtd’sturnoverfortheyearended31March2015was￡240,000(VATexclusive).–NocturneLtd’sturnoverfortheyearasawholeforVATpurposescomprised86%taxablesuppliesand14%exemptsupplies.–TheinputVATsufferedbyNocturneLtdonexpenditureduringtheyearended31March2015was:–NocturneLtdexpectsitsturnoverandexpenditurefigurestoincreasebyapproximately25%nextyear.–SigliohasheardaboutanannualtestforcomputingtheamountofrecoverableinputVATduringanaccountingperiodandwouldlikemoreinformationaboutthis.Required:

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问答题Sakura requires advice on the receipt of insurance proceeds, the sale of a painting in exchange for a boat and the implications of making an error when preparing his tax return. The following information has been obtained from a telephone conversation with Sakura. Sakura: - Is a higher rate taxpayer who is resident, ordinarily resident and domiciled in the UK. - Is finalising his tax return for the tax year 2011/12. - Has not previously made any gifts or disposals for the purposes of capital gains tax or inheritance tax other than those set out below. - Does not expect to make any gifts or disposals for the purposes of capital gains tax or inheritance tax in the tax years 2012/13 or 2013/14 other than those set out below. - Has received insurance proceeds of ￡67,000. - Intends to sell a painting to his son, Cashel, in exchange for a boat. The insurance proceeds of ￡67,000: - The insurance proceeds were paid to Sakura on 1 June 2012. - The insurance proceeds relate to the destruction of an antique china figurine on 1 March 2012. - Sakura paid ￡28,000 for the figurine on 1 April 2008. - The figurine had a market value of ￡80,000 on 1 March 2012. - Sakura intends to use the money to purchase a modern glass figurine for ￡59,000. Exchange of painting for boat: - Sakura intends to sell a painting with a market value of ￡48,000 to his son, Cashel. - The consideration for the sale will be a boat owned by Cashel that has a market value of ￡25,000. - The painting and the boat cost ￡22,000 and ￡37,000 respectively. Sakura's tax return: - Sakura always prepares his tax returns in an honest manner. - However, he is aware that he could still make an honest mistake. Required (a) - Explain, with supporting calculations where necessary, the capital gains tax and inheritance tax implications for Sakura of the receipt of the insurance proceeds and the sale of the painting in exchange for the boat. - Advise Sakura of the actions he should take in relation to his plans in order to minimise his capital gains tax liability and point out any matter(s) that would need to be resolved with HM Revenue and Customs. Note: you should clearly identify the tax years relevant to the disposals and the due date of payment of any minimised capital gains tax liability. (b) State, with reasons, whether there will be any capital gains tax and/or inheritance tax implications for Cashel from the disposal of the boat. (c) Explain the manner in which a penalty would be calculated if Sakura were to make an honest mistake when completing his tax return. 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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