(b) For this part, assume today’s date is 1 May 2010.Bill and Ben decided not to sell their company, and instead expanded the business themselves. Ben, however,is now pursuing other interests, and is no longer involved with the day to day activities of Fl

题目

(b) For this part, assume today’s date is 1 May 2010.

Bill and Ben decided not to sell their company, and instead expanded the business themselves. Ben, however,

is now pursuing other interests, and is no longer involved with the day to day activities of Flower Limited. Bill

believes that the company would be better off without Ben as a voting shareholder, and wishes to buy Ben’s

shares. However, Bill does not have sufficient funds to buy the shares himself, and so is wondering if the

company could acquire the shares instead.

The proposed price for Ben’s shares would be ￡500,000. Both Bill and Ben pay income tax at the higher rate.

Required:

Write a letter to Ben:

(1) stating the income tax (IT) and/or capital gains tax (CGT) implications for Ben if Flower Limited were to

repurchase his 50% holding of ordinary shares, immediately in May 2010; and

(2) advising him of any available planning options that might improve this tax position. Clearly explain any

conditions which must be satisfied and quantify the tax savings which may result.

(13 marks)

Assume that the corporation tax rates for the financial year 2005 and the income tax rates and allowances

for the tax year 2005/06 apply throughout this question.

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相似问题和答案

第1题：

Clerk: Please fill out the form.

Guest: All right. , please?

Clerk: It's August, the thirteenth.

A． What day is it today

B． What's the number

C． What's the date today

D． What's the time now

正确答案：C
职员请客人填表，客人提问后，职员回答今天是八月十三号。选项C(今天几号?)与职员的回答匹配，选项A(今天星期几?)、B(数目：黾什么?)和D(现在是什么时间?)与职员的回答无语义联系，不正确。

第2题：

下列程序的运行结果是()。 include main() {stmct date {int year,month,day; }today;

下列程序的运行结果是( )。

#include＜stdio.h＞

main()

{stmct date

{int year,month,day；

}today；

primf("%d\n",sizeof(struct date));

}

A．8

B．6

C．10

D．12

正确答案：B
解析：解答本题需要注意两个知识点：①结构体变量的长度是其内部成员长度的总和，本题中，struct date中包含year、month、day这3个整型变量，一个整型变量占2个字节：②sizeof是求所占字节数的运算符。

第3题：

I felt so bad all day yesterday that I decided this morning I couldn’t face ________ day like that.

A. other B. another C. the other D. others

正确答案：B

第4题：

-________?

-It's Sunday.

A、What day is it today

B、What date is it today

C、What's the date

D、What's day

参考答案：A

第5题：

(b) Draft a report as at today’s date advising Cutlass Inc on its proposed activities. The report should cover the

following issues:

(i) The rate at which the profits of Cutlass Inc will be taxed. This section of the report should explain:

– the company’s residency position and what Ben and Amy would have to do in order for the company

to be regarded as resident in the UK under the double tax treaty;

– the meaning of the term ‘permanent establishment’ and the implications of Cutlass Inc having a

permanent establishment in Sharpenia;

– the rate at which the profits of Cutlass Inc will be taxed on the assumption that it is resident in the

UK under the double tax treaty and either does or does not have a permanent establishment in

Sharpenia. (9 marks)

正确答案：
(b) Report to the management of Razor Ltd
To           The management of Razor Ltd
From      Tax advisers
Date         6 June 2007
Subject    The proposed activities of Cutlass Inc
(i) Rate of tax on profits of Cutlass Inc
When considering the manner in which the profits of Cutlass Inc will be taxed it must be recognised that the system of
corporation tax in Sharpenia is the same as that in the UK.
The profits of Cutlass Inc will be subject to corporation tax in the country in which it is resident or where it has a
permanent establishment. It is desirable for the profits of Cutlass Inc to be taxed in the UK rather than in Sharpenia as
the rate of corporation tax in the UK on annual profits of ￡120,000 will be 19% whereas in Sharpenia the rate of tax
would be 38%.
Residency of Cutlass Inc
Cutlass Inc will be resident in Sharpenia, because it is incorporated there. However, it will also be resident in the UK if
it is centrally managed and controlled from the UK. For this to be the case, Amy and Ben should hold the company’s
board meetings in the UK.
Under the double tax treaty between the UK and Sharpenia, a company resident in both countries is treated as being
resident in the country where it is effectively managed and controlled. For Cutlass Inc to be treated as UK resident under
the treaty, Amy and Ben would need to ensure that all key management and commercial decisions are made in the UK
and not in Sharpenia.
Permanent establishment
A permanent establishment is a fixed place of business, including an office, factory or workshop, through which the
business of an enterprise is carried on. A permanent establishment will also exist in a country if contracts in the
company’s name are habitually concluded there.
The trading profits of Cutlass Inc will be taxable in Sharpenia if they are derived from a permanent establishment in
Sharpenia even if it can be established that Cutlass Inc is UK resident under the double tax treaty.
Double taxation
If Cutlass Inc is UK resident but has a permanent establishment in Sharpenia, its trading profits will be subject to
corporation tax in both the UK and Sharpenia with double tax relief available in the UK. The double tax relief will be the
lower of the UK tax and the Sharpenian tax on the trading profits. Accordingly, as the rate of tax is higher in Sharpenia
than it is in the UK, there will be no UK tax to pay on the company’s trading profits and the rate of tax on the profits
would be the rate in Sharpenia, i.e. 38%.
If Cutlass Inc is UK resident and does not have a permanent establishment in Sharpenia, its profits will be taxable in
the UK at the rate of 19% and not in Sharpenia.

第6题：

有以下程序： Class Date { public： Date(int y，int m，mt d)； { year=y； month＝m； day＝d； } Date(int y＝2000) { year＝y； month＝10； day＝1； } Date(Date &D) { year＝d.year； month＝d.month； day＝d.day； } Void prin

A．2

B．3

C．4

D．5

正确答案：B
解析：本题考核拷贝构造函数。上述程序中，拷贝构造函数一共被调用了3次：第一次是在执行语句Date date3(date1)；时，用已经建立的对象date1对正在建立的对象date3进行初始化；第二次是在调用fun函数时，由于是传值调用，因此实参对象date3要对形参对象d进行初始化；第三次是在执行fun函数中的返回语句return temp时，系统初始化一个匿名对象时使用了拷贝构造函数。

第7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 company

that 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 accumulated

a large cash balance of ￡180,000, which is to be used to purchase a new factory. However, Bill and Ben have

received an offer from a rival company, which they are considering. The offer provides Bill and Ben with two

alternative 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 offer

terms 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 March

2006 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 your

answer. (5 marks)

正确答案：

As a result, Bill and Ben would each be better off by ￡15,005 (69,142 – 54,137). If the cash were extracted by way
of dividend.
Tutorial note: In this answer the employers’ national insurance liability on the salary has been ignored. Credit would be
given to a candidate who recognised this issue.

第8题：

–____________________? –It’s Sunday.

(A) What time is it?

(B) When is it?

(D) What day is today?

正确答案：D

解答参考：D 本题考查 “今天是星期几”的问法，

正确答案：D
解答参考：D 本题考查 “今天是星期几”的问法，正确答案D。

第9题：

听力原文：M: Oh, my God! Jessica. It's five p. m. now. Tomorrow is Saturday. The credit will expire on Sunday. Weekend is non-business day. We cannot make it today. What shall we do?

W: Don't worry. Banks will accept presentation on the following business day.

Q: When will the bank deal with the credit if the expiry date of a credit fails on a non-business day?

(19)

A．On every business day.

B．On Tuesday.

C．On Wednesday.

D．On the following business day.

正确答案：D
解析：根据女士的回答，贷款在假期期间到期时，银行将在下一个工作日办理。

第10题：

回答What's today's date? ／What's the date today?正确的句子是:()

A、It's cold today.

B、It's February AD.

C、It's Friday.

D、It's Valentine's Day.

参考答案：B

(b) For this part, assume today’s date is 1 May 2010.Bill and Ben decided not to sell their company, and instead expanded the business themselves. Ben, however,is now pursuing other interests, and is no longer involved with the day to day activities of Fl

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