(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.
相似考题
更多“(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”相关问题
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第1题：
下列程序的运行结果是()。 includemain() {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2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3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4题：
有以下程序： class Date { public： Date(int y,int m,int 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 print () { cout＜＜year＜＜"．"＜＜month＜＜"."＜＜day＜＜end1； } private： int year,month,day； }； Date fun(Date D) { Date temp； temp=d； return temp； } int main() { Date date1(2000,1，1)，date2(0，0,0)； Date date3(date1)； date2=fun(date3)； return 0； } 程序执行时，Date类的拷贝构造函数被调用的次数是
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Datedate3(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returntemp；时，系统用返回初始化一个匿名对象时使用了拷贝构造函数。 -
第5题：
下列程序的运行结果为()。includemain(){struct date {int year,month,day; }today; pr 下列程序的运行结果为( )。 #include＜stdio.h＞ main() { struct date {int year,month,day; }today; printf("%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，structdate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6题：
以下程序的运行结果是()。includemain(){st,uct date {int year,month,day;}today; pri 以下程序的运行结果是( )。 #include ＜stdio．h＞ main() { st，uct date {int year，month，day；}today； printf("%d\n"，sizeof(struct date))； }
A．6
B．8
C．10
D．12
正确答案：A
解析：结构体变量的长度是其内部成员总长度之和，在本题中，structdate中包含year，month，day三个整型变量。通常一个整型变量占2个字节，因此，用sizeof求得该结构体变量的长度为6个字节。 -
第7题：
What day is it today?（）
AIt's March
BIt's a fine day today.
CIt's March today.
DIt's Monday.
D
略 -
第8题：
What is the key objective of the plan phase？（）
- A、Identify the activities involved in installing and configuring equipment at a customer’s site or sites
- B、Describe the day-to-day activities required to support， manage， and monitor a newly implemented system
- C、Access current network readiness， site readiness， and operational readiness in preparation for designing a solution proposal
- D、Gain an understanding of high-level business and technical requirements
正确答案:C -
第9题：
What is the key objective of the plan phase？ Select exactly 1 answer（s） from the following：（）。
- A、identify the activities involved in installing and configuring equipment at a customer’s site or sites
- B、Describe the day-to-day activities required to support， manage， and monitor a newly implemented system
- C、Assess current network readiness， site readiness， and operational readiness in preparation for designing a solution proposal
- D、Gain an understanding of high-level business and technical requirement
正确答案:A -
第10题：
单选题What do you think “florists” do?AThey sell flowers.
BThey make bread.
CThey sell clothes for Mother’s Day and Father’s Day.
正确答案： A解析：
考 点：推理题。题目要我们推测florists是干什么的。本词的构词形式易使人联想到flower这个词语。并且，文章之前已经提到了母亲节需要戴花，而这个节日里能够做很多生意的当然也是少不了花店。由此可见，本题的正确答案应为A项。 -
第11题：
问答题根据所提供的信息和语言素材进行教学设计。 A: Hi, what day is today? B: It’s Monday. A: What’s the date today? B: It’s June the 4th. A: What day was it yesterday? B: It was Sunday. A: What was the date yesterday? B: It was June the 3rd. 针对七年级学生特点，写出其教学目标、重点和难点，设计一个活动方案。正确答案：
(1)教学目标:
①学习一般过去时was的用法。
②复习星期的单词和日期的表示方法。
③掌握单词was,yesterday等词汇的使用。
(2)教学重难点:
①was的使用。
②一般过去时的初步使用,与过去具体时间状语连用。
(3)活动方案:
①利用日历等实物,让学生带好日历,进行小组合作等。
②利用动画等,增强直观效果。解析： 暂无解析 -
第12题：
单选题It is a company’s policy to shut down all workstations at the end of the day. However, the majority of employees are leaving disks in their workstations and upon start up the next morning they are receiving a ‘NTLDR is missing’ error. Which of the following is a possible solution?（）AMake a daily announcement to remove all disks before departing for the day.
BChange the Boot order in the BIOS.
CMake it a part of the evening checks to ensure all disks are removed.
DMake a company policy that states that it is unlawful to leave disks in the machines.
正确答案： C解析： 暂无解析 -
第13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14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15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
-
第16题：
可以计算当前日期所处年份的表达式是（ ）。
A. Day(Date)
B. Year(Date)
C. Year(Day(Date))
D. Day(Year(Date)1
正确答案：B
本题考查日期函数的知识。可以使用 Year函数来求取某个日期型数据的年份，使用Date函数来求取当前日期，正确的写法应该是：Year(Date)。
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第17题：
有以下程序： class Date { public: Date(int y,int m,int 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 print() { cout＜＜year＜＜"."＜＜month＜＜"."＜＜day＜＜endl; } private: int year,month,day; }; Date fun(Date d) { Date temp; temp = d; resurn temp; } int main () { Date date1 (2000,1,1),date2 (0,0,0); Date date3 (date1); date2 = fun(date3); return 0; } 程序执行时，Date类的拷贝构造函数被调用的次数是
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，系统用返回初始化一个匿名对象时使用了拷贝构造函数。 -
第18题：
资料：Bank CD is the instrument uniformly figuring in the investment options of most investors. Bank of India CDs are safe, FDIC insured & offer decent returns. There is no brokerage, no fees or hidden costs. However, the Bank may impose a fee for administrative expenses involved in any legal action in connection with the CD. Look at our ‘Star CD’ plan below.
High Interest: Higher on Large amount
Our rates on certificate of deposits are among the best in the industry. The rate may vary on day-to day basis. For CD’s of above $250,000.00, the interest is simple i.e not compounded; therefore, annual percentage yield is same as annual interest rate. The interest is payable on the day of maturity of deposit. Interest paid during the year is reported to Internal Revenue Services. For today’s rates please refer to Current Rates of Interest on STAR CDs.
Maturity Period: Flexible to your needs
You may choose any maturity date with a minimum period of 7 days to a maximum period of 1 year to suit your needs. Your CD is automatically renewed for the same period in absence of any other instruction, at the ruling rate of interest on the date of renewal. There is no grace period for automatic renewal of deposits on maturity. For deposits issued for 1 year or more, we send maturity notices to the depositors 2 to 4 weeks before the due date.
Minimum Amount: Easy to Start
The minimum amount accepted is USD 2000
Other Features:
1.FDIC Insurance Up to $100,000
2.Facility to Open Joint & Corporate Accounts
Additional Deposits:
Additional amounts deposited into an account will be treated as fresh deposits & separate certificates of deposits will be issued for such deposits.
Early Withdrawal:
Withdrawal of deposit before its date of maturity may be allowed at bank’s discretion. In that event, interest will be paid at the rate applicable for the period for which the deposit remained with the bank or the contracted rate, whichever is lower, as prevailing on the date of deposit, less one percent. However, no interest shall be paid on the deposit which runs for less than 30 days. There is no other penalty or charge on early withdrawal.
According to the passage, which of the following is NOT true about Star CD? （ ）A.The minimum amount to invest is USD 2000.
B.You may choose any maturity date as you wish.
C.The rates on certificate of deposits may vary day to day.
D.Separate certificates of deposits will be issued for additional deposits.答案：B解析：本题考查细节理解。
【关键词】not true; about Star CD
【主题句】
第七段The minimum amount accepted is USD 2000. 最低投资金额为2000美元。
第五段You may choose any maturity date with a minimum period of 7 days to a maximum period of 1 year to suit your needs. 您可以选择任何到期日，最短期限为7天，最长期限为1年，以满足您的需求。
第三段The rate may vary on day-to day basis. 利率可能每天都有所不同。
倒数第三段Additional amounts deposited into an account will be treated as fresh deposits & separate certificates of deposits will be issued for such deposits. 存入账户的额外金额将被视为新鲜存款，并将为此类存款发放单独的存款凭证。
【解析】题目意为“关于‘星光’大额存款计划，以下哪个选项不正确？”。选项A意为“最低投资金额为2000美元”；选项B意为“您可以根据您的意愿选择任何到期日”；选项C意为“利率可能每天都有所不同”；选项D意为“将为额外存款发放单独的存款证明书”。根据主题句，到期日必须在7天到1年之间，因此不能随意选择到期日，故选项B错误。 -
第19题：
What day is it today?（）
- A、It's March
- B、It's a fine day today.
- C、It's March today.
- D、It's Monday.
正确答案:D -
第20题：
下面哪一个函数返回系统时间（）。
- A、DATE（）
- B、NOW（）
- C、TIME（）
- D、DAY（）
正确答案:C -
第21题：
It is a company’s policy to shut down all workstations at the end of the day. However, the majority of employees are leaving disks in their workstations and upon start up the next morning they are receiving a ‘NTLDR is missing’ error. Which of the following is a possible solution?（）
- A、Make a daily announcement to remove all disks before departing for the day.
- B、Change the Boot order in the BIOS.
- C、Make it a part of the evening checks to ensure all disks are removed.
- D、Make a company policy that states that it is unlawful to leave disks in the machines.
正确答案:B -
第22题：
单选题What day is it today?（）AIt's March
BIt's a fine day today.
CIt's March today.
DIt's Monday.
正确答案： B解析： 暂无解析 -
第23题：
单选题Why did Tom pretend not to see Ben?ABecause he wanted Ben to believe that he was enjoying the work.
BBecause he would like to try his best to attract Ben’s attention.
CBecause he did not want Ben to see the fact that he had to work.
DBecause he was afraid that Ben might laugh at him if he saw him.
正确答案： C解析：
细节理解题。第一段第三句提到“Then he had an idea!”，接着Tom认真工作。由此可知，Tom假装没看见Ben的目的是让他以为自己很享受这份工作。