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低分子量肝素(LMWH)抗凝治疗中,选用的监测指标是
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Bex has recently left employment and entered into a business partnership with Amy. Bex requires advice in respect of a loan to the partnership, the calculation of her share of profits and the tax treatment of her redundancy payment.
Bex:
– Is resident and domiciled in the UK.
– Received an annual salary of ￡120,000 from her former employer, Cape Ltd.
– Was made redundant by Cape Ltd on 30 September 2015.
– Joined Amy, a sole trader, to form. a partnership on 1 January 2016.
– Has no other source of income.
Amy and Bex partnership:
– Will prepare its first set of accounts for the 16-month period to 30 April 2017.
– Is expected to make a tax-adjusted profit of ￡255,000 (before deducting interest and capital allowances) for the period ending 30 April 2017.
– The tax written down value on its main pool at 1 January 2016 is ￡nil.
– Except for the computer referred to below, no further assets will be purchased by either Amy or Bex for use in the partnership in the period ending 30 April 2017.
Profit sharing arrangements:
– The partnership’s profit sharing agreement is as follows:
Bex – loans:
– In addition to her capital contribution, Bex will make a ￡20,000 loan to the partnership on 1 August 2016. The partnership will use this money wholly for business purposes.
– This loan will be financed by a ￡25,000 personal loan from Bex’s bank, taken out on the same date.
– The remaining ￡5,000 of the bank loan will be used to purchase a computer for use in the partnership. Bex will have 20% private use of this computer.
– Both the loan from Bex to the partnership and the personal bank loan to Bex will carry interest at the rate of 5% per annum.
Bex – redundancy package from Cape Ltd:
– The package comprised a ￡22,000 statutory redundancy payment and an additional ex-gratia payment of ￡48,000.
– Bex also received three months’ salary in lieu of notice, as specified in her contract of employment.
Required:
(a) (i) Explain, with the aid of calculations, the tax deductions which will be available in respect of the loan interest payable on both the loan from Bex to the partnership and the personal bank loan to Bex. (7 marks)
(ii) In respect of the period ending 30 April 2017, show the allocation between the partners of the taxable trading profit of the partnership. (4 marks)
(iii) Calculate Bex’s taxable trading income in respect of her share of the partnership profits for all relevant tax years. Note: Your answer to (a)(iii) should clearly state the tax years and basis periods involved. (3 marks)
(b) Explain the income tax implications for Bex of the receipt of the redundancy package from Cape Ltd and calculate her total income tax liability for the tax year 2015/16. (6 marks)
弥散性血管内凝血的基本病变是
肝素的抗凝作用不包括
Section B – TWO questions ONLY to be attempted
Your client, Eric, requires advice on the capital gains tax implications arising from the receipt of insurance proceeds and the disposal of some shares, and the inheritance tax reliefs available in respect of assets in his estate at death. His son Zak requires advice regarding the application of the personal service company (IR35) legislation.
Eric:
– Is UK resident and domiciled.
– Is a higher rate taxpayer.
– Is in ill health and is expected to die within the next few months.
Capital transactions in the tax year 2014/15:
– Eric made no disposals for capital gains tax purposes in the tax year 2014/15 other than those detailed below.
– Eric received insurance proceeds of ￡10,000 following damage to a valuable painting.
– Eric sold half of his shareholding in Malaga plc for ￡11·50 per share.
Damaged painting:
– Eric purchased the painting for ￡46,000 in July 2012.
– The painting was damaged in October 2014 such that immediately afterwards its value fell to ￡38,000.
– The insurance proceeds of ￡10,000 were received by Eric on 1 December 2014.
– Eric has not had the painting repaired.
Malaga plc shares:
– Malaga plc is a quoted trading company with 200,000 issued shares.
– 80% of Malaga plc’s chargeable assets have always been chargeable business assets.
– Eric was given 12,000 shares in Malaga plc by his sister on 1 April 2010, when they were valued at ￡126,000.
– Eric’s sister had purchased the shares for ￡96,000 on 1 March 2009.
– Gift relief was claimed in respect of the gift of the shares to Eric on 1 April 2010.
– Eric paid the inheritance tax arising in respect of this gift following his sister’s death on 1 September 2011.
– Eric has never worked for Malaga plc.
– Eric sold 6,000 shares in Malaga plc on 1 March 2015.
Assets owned by Eric and a previous lifetime gift:
– Eric owns farmland in the UK, which has been leased to a tenant farmer for the last ten years.
– The farmland has a market value of ￡420,000 and an agricultural value of ￡340,000.
– Eric’s other assets, excluding the remaining Malaga plc shares, are valued at ￡408,000.
– Eric has made only one previous lifetime gift, of ￡60,000 cash to his son Zak on 1 July 2009.
Zak:
– Is the sole shareholder, director and employee of Yoyo Ltd, a company which provides consultancy services.
– In the year ended 31 March 2016, Yoyo Ltd’s gross fee income from relevant engagements performed by Zak will be ￡110,000.
– In the tax year 2015/16, Zak will draw a salary of ￡24,000 and dividends of ￡50,000 from Yoyo Ltd.
– Neither Yoyo Ltd nor Zak has any other source of income.
Required:
(a) Calculate Eric’s total after-tax proceeds in respect of the two capital gains tax disposals in the tax year 2014/15. (6 marks)
(b) (i) On the assumption that Eric dies on 31 March 2016, advise on the availability and effect (if any), of agricultural property relief, business property relief and quick succession relief in respect of the farmland and the retained shares in Malaga plc.
Note: You are not required to prepare calculations for this part of the question. (6 marks)
(ii) Explain, with the aid of calculations, the impact on the inheritance tax liability arising on Eric’s death if Eric does not die until 1 August 2016. (3 marks)
(c) Calculate Zak’s taxable income for the tax year 2015/16 if the personal service company (IR35) legislation were to apply to the fee income received by Yoyo Ltd. (5 marks)
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