案例分析题Your client, Eric

案例分析题Meg is an unincorporated sole trader

案例分析题Juanita has contacted you following the death of her husband, Don. As the executor of his estate, she is seeking advice regarding the inheritance tax liability arising as a result of his death on shares which he owned. She also requires advice on the timing of her ceasing to trade. Don: Died on 1 July 2016. Had always been UK resident and domiciled. Was married to Juanita, and they have one daughter, Lexi. Lifetime gifts: Don made only two lifetime gifts. On 9 May 2011, Don gifted his overseas villa to Lexi. The villa was valued at 355,000 on 9 May 2011, and at 370,000 on 1 July 2016. On 1 March 2013, on the advice of a financial adviser, Don gifted 3,500 of his shares in Estar Ltd to Lexi. Prior to receiving this advice, Don had been planning to leave these shares to Lexi on his death. Under the terms of Dons will, Dons cousin will inherit the remaining 3,500 shares in Estar Ltd owned by Don at his death. Estar Ltd: Is an investment company; no business property relief is available on the transfer of its shares. Before the gift on 1 March 2013, Don owned 7,000 ordinary shares in Estar Ltd. The remaining 3,000 ordinary shares issued by Estar Ltd are held by Juanita. The shares were valued as follows: Percentage shareholding Value per share 1 March 2013 1 July 2016 0%50% 900 1080 51%75% 1500 1800 76%100% 2000 2400 Juanita: Has carried on a business as a sole trader for many years, preparing accounts to 30 June annually. Following Dons death, intends to cease trading and retire. Would like to cease trading on 28 February 2017, in which case the business will be sold to an unconnected person. Is willing to continue to trade until 30 April 2017, when Lexi will be able to take over the business. Does not anticipate having any other source of taxable income in either of the tax years 2016/17 or 2017/18. Juanitas business: Has taxable trading profits of 51,000 for the year ended 30 June 2016. Has budgeted tax-adjusted profits of 48,000 (before capital allowances) in the period ending 28 February 2017. Has budgeted further taxable profits of 4,000 per month if Juanita continues to trade after 28 February 2017. Has overlap profits from commencement of 17,000. The tax written down value on the main pool was nil at 1 July 2016. The market value of the assets in the main pool will be 6,000 at the date of cessation. Required:

案例分析题Your manager has had a meeting with Jonny who is establishing a new business. An extract from an email from your manager, a schedule and a computation are set out below. Extract from the email from your manager Jonny was born in 1968. His new business will begin trading on 1 November 2015. Jonny will use an inheritance he received following the death of his mother to finance this new venture. We have been asked to advise Jonny on his business and his inheritance. Some of the work has already been done; I want you to complete it. Please prepare a memorandum for Jonnys client file addressing the following issues: (a) Unincorporated business I attach a schedule which sets out Jonnys recent employment income and his plans for the new business. I think you will find it useful to read the schedule before you go through the rest of this email. You should assume that Jonny does not have any other sources of income or any taxable gains in any of the relevant tax years. (i) Jonnys post-tax income Jonny has asked for an approximation of his post-tax income position for the first two trading periods. I want you to prepare calculations in order to complete the following table, assuming that any available trading loss reliefs will be claimed in the most beneficial manner. You should include explanations of the options available to relieve the loss, clearly identifying the method which will maximise the tax saved (you do not need to consider carrying the loss forward). Table to be completed Include a brief explanation as to why these calculations are only an approximation of Jonnys budgeted post-tax income. (ii) Salesmen Jonny intends to hire two salesmen to get the business started. Their proposed contractual arrangements are as set out in the attached schedule. Explain which of the proposed contractual arrangements with the salesmen indicate that they would be self-employed and state any changes which should be made to the other arrangements in order to maximise the likelihood of the salesmen being treated as self-employed. (iii) New contracts for the business Jonny is hoping to obtain contracts with local educational establishments and has asked us to help. One of our clients is a college and an ex-client of ours provided services to a number of schools and colleges. Accordingly, we have knowledge and experience in this area. Explain the extent to which it is acceptable for us to use the knowledge we have gained in respect of our existing client and ex-client to assist Jonny. (b) Jonnys inheritance from his mother Jonnys mother died on 31 July 2015. She left the whole of her estate, with the exception of a gift to charity, to Jonny. I attach a computation of the inheritance tax due; this was prepared by a junior member of staff and has not yet been reviewed. I can confirm, however, that all of the arithmetic, dates and valuations are correct. In addition, there were no other lifetime gifts, and none of the assets qualified for business property relief. I want you to review the computation and identify any errors. You should explain each of the errors you find and calculate the value of the inheritance which Jonny will receive after inheritance tax has been paid. Tax manager Schedule Employment income and plans for the new business Jonnys income Jonny worked full-time for many years until 30 June 2013 earning a salary of 6,000 per calendar month. From 1 July 2013, he worked part-time earning a salary of 2,000 per calendar month until he ceased employment on 31 March 2015. Two budgets have been prepared for Jonnys business based on customer demand being either strong or weak. You should assume that no tax adjustments are required to Jonnys budgeted profit/loss figures for the first two trading periods. For strong demand, the taxable trading profit for the first two tax years has been computed; these figures are correct and you do not need to check them. You will, however, need to calculate the equivalent figures for weak demand. Salesmen Jonny is proposing to enter into the following contractual arrangements with two part-time salesmen: They will work on Tuesday and Wednesday mornings each week for a two-month period. They will be paid a fee of 300 for each new sales contract obtained. No other payments will be made. They will use their own cars. Jonny will lend each of them a laptop computer. Computation Inheritance tax payable on the death of Jonnys mother Required: Prepare the memorandum as requested in the email from your manager. The following marks are available:

案例分析题Your firm has been asked to provide advice to Granada Ltd, and one of its shareholders, Maria

案例分析题Your manager has been advising a client, Waverley

案例分析题Demeter has recently taken up a new employment and is seeking advice on the tax treatment of certain components of his remuneration package, and the relief(s) available to reduce the chargeable gain on the sale of his house. Demeter: Is UK resident and domiciled. Commenced employment with Poseidon Ltd on 1 December 2018. Will have no source of income, other than from Poseidon Ltd, in all relevant future tax years. Will be a higher rate taxpayer in all relevant future tax years. Has relocated to London, from Manchester, a city more than 150 miles north of London, to take up this employment. Remuneration package from Poseidon Ltd: Demeter will receive an annual salary of 130,000. On 1 December 2018, Poseidon Ltd made a one-off lump sum payment of 20,000 to Demeter as an inducement to take up employment with the company. Poseidon Ltd paid Demeter 5,000 towards his costs of relocating to London. The company is also paying him 1,500 each month for four months from 1 December 2018 towards renting accommodation in London until he purchases a new house on 1 April 2019. On 1 December 2018, Demeter was granted share options in Poseidon Ltds unapproved share option scheme. From 6 April 2019, Demeter will participate in Poseidon Ltds approved occupational pension scheme. Relocation to London: Demeter incurred costs in relation to his relocation to London of 6,000. This amount includes estate agent fees of 2,800 in connection with the sale of his house in Manchester on 31 October 2018. Demeter signed a four-month lease for a flat in London from 1 December 2018 at a monthly rental of 1,700. House in Manchester: Demeter purchased the house on 1 May 2005 and lived in it as his main residence. Demeter let the top floor of the house (comprising 30% of the total house) to tenants from 1 May 2007 to 31 October 2018. The tenants did not share Demeters living accommodation or take meals with him. Demeter continued to occupy the remainder of the house as his main residence until 31 October 2018, when the entire house was sold. The sale gave rise to a gain, before any reliefs, of 94,000. Demeter did not own any other house throughout the period from 1 May 2005 to 31 October 2018. Demeter pension contributions: Demeter has made tax-allowable contributions of 40,000 (gross) to a personal pension plan for the last five tax years and will continue to do so in future tax years. From the tax year 2019/20, Poseidon Ltd will contribute an amount equal to 10% of Demeters annual salary to its approved occupational pension scheme. Demeter will make no contributions to Poseidon Ltds occupational pension scheme. Poseidon Ltds share option scheme: On 1 December 2018, Poseidon Ltd granted Demeter options over 3,000 shares in its unapproved share option scheme at a 5% discount on the market value of the shares on that date. The market value of Poseidon Ltd shares on 1 December 2018 was 420 per share. Demeter will exercise the options on 6 April 2024, and immediately sell the shares. Poseidon Ltd believes that the market value of its shares on 6 April 2024 will be 600 per share. Required:

案例分析题Your manager has received a letter from Christina

案例分析题 Your manager has asked you to take charge of some work in connection with the Heyer Ltd group of companies. A schedule of information from the client files and an email from your manager detailing the work he requires you to do are set out below Heyer Ltd group schedule of information from the client files Group structure General information All of the companies are resident in the UK and prepare accounts to 31 December each year. The figures given below of taxable total profits (TTP) take account of all possible rollover relief claims. None of the companies has received any dividend income from non-group companies. Specific information Mantet Ltd Mantet Ltd has TTP of between 40,000 and 50,000 every year. Newell Rap Ltd Heyer Ltd acquired Newell Rap Ltd on 1 May 2016. Newell Rap Ltd has a capital loss brought forward as at 1 January 2017 of 94,000. This loss arose on a sale of land on 1 February 2014. Orin Hod Ltd The TTP of Orin Hod Ltd exceed 200,000 every year. In the year ending 31 December 2017 Orin Hod Ltd will make chargeable gains of 86,000. Other 100% owned companies Each of these companies has TTP of more than 130,000 every year. Four of them will have substantial chargeable gains in the year ending 31 December 2017. Five of them will have capital losses in the year ending 31 December 2017. Heyer Ltd group schedule of information from the client files (continued) Group restructuring It is intended that the trade and assets of five group companies (Newell Rap Ltd and four of the other 100% owned companies) will be sold to Lodi Ltd at some point in January 2018. The assets of the five companies, including the business premises, machinery and equipment will be sold to Lodi Ltd for their market value. The tax written down value of the main pool of each of the five companies immediately prior to the sale will be zero. Pink Time Ltd Heyer Ltd intends to incorporate a new subsidiary, Pink Time Ltd, on 1 September 2017. Pink Time Ltd will have a monthly turnover of 35,000. All of its sales will be to members of the public and will be zero rated for the purposes of value added tax (VAT). Email from your manager dated 8 June 2017 Please carry out the following work: (a) Group planning The groups objective is to minimise the corporation tax payable in instalments by group companies in respect of the year ended 31 December 2017. I have asked Cox, our tax assistant, to carry out this work and I have provided him with the details of the companies budgeted results for 2017. There is no group relief available within the group. Cox has not done this type of work before and he has had very little experience of capital gains groups, so I want you to prepare some guidance for him. The guidance should consist of explanations of: the circumstances in which a member of the Heyer Ltd group would be required to pay corporation tax in instalments, assuming that the profits threshold should be divided by 18; which companies are members of a capital gains group; how Cox should determine the amount of chargeable gains and capital losses to transfer between the group companies in order to achieve the groups objective; and the relevance to the groups objective of the specific information provided in the schedule of information. (b) Group restructuring Identify, with reasons, the implications of the proposed group restructuring in relation to chargeable gains, stamp duty land tax and capital allowances, and what will happen to any capital losses belonging to the five companies whose trade and assets are transferred. (c) Pink Time Ltd Explain whether it will be compulsory for Pink Time Ltd to register for value added tax (VAT) and why the company would benefit from registering. (d) Disclosure of transfer pricing It has been realised by the management of Heyer Ltd that transfer pricing adjustments should have been made in respect of the year ended 31 December 2013 for three of the companies in the group. The corporation tax liability of the group was understated as a result of this non-disclosure. I have already explained the interest and penalties which may be charged in respect of this. I want you to list the other matters which need to be considered, by us, as tax advisers to the group, and by the management of the group, in relation to the disclosure or non-disclosure of this information to HM Revenue and Customs (HMRC). Tax manager Required: Carry out the work requested in the email from your manager. The following marks are available:

案例分析题Your client, Jessica, has requested advice in relation to the tax liability arising on a redundancy payment, the options available to relieve her share of a partnership trading loss, and the maximum contribution she can make to a personal pension scheme

案例分析题Your manager has had a meeting with Snowdon

案例分析题Your manager has had a meeting with Gail

案例分析题Your firm has been asked to provide advice to Methley Ltd, a close company, in respect of the provision of share incentives, a motor car and an interest-free loan to employees

问答题1.YourmanagerhasreceivedaletterfromJodieinconnectionwithherproposedemigrationfromtheUK.Extractsfromtheletterandfromanemailfromyourmanageraresetoutbelow.ExtractfromtheletterfromJodieExtractfromanemailfromyourmanagerRequired:PreparetheparagraphsforinclusioninaletterfromyourmanagertoJodieasrequestedintheemailfromyourmanager.Thefollowingmarksareavailable:

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