2 Graeme, aged 57, is married to Catherine, aged 58. They work as medical consultants, and both are higher ratetaxpayers. Barry, their son, is aged 32. Graeme, Catherine and Barry are all UK resident, ordinarily resident anddomiciled. Graeme has come to y
题目
2 Graeme, aged 57, is married to Catherine, aged 58. They work as medical consultants, and both are higher rate
taxpayers. Barry, their son, is aged 32. Graeme, Catherine and Barry are all UK resident, ordinarily resident and
domiciled. Graeme has come to you for some tax advice.
Graeme has invested in shares for some time, in particular shares in Thistle Dubh Limited. He informs you of the
following transactions in Thistle Dubh Limited shares:
(i) In December 1986, on the death of his grandmother, he inherited 10,000 ￡1 ordinary shares in Thistle Dubh
Limited, an unquoted UK trading company providing food supplies for sporting events. The probate value of the
shares was 360p per share.
(ii) In March 1992, he took up a rights issue, buying one share for every two held. The price paid for the rights
shares was ￡10 per share.
(iii) In October 1999, the company underwent a reorganisation, and the ordinary shares were split into two new
classes of ordinary share – ‘T’ shares and ‘D’ shares, each with differing rights. Graeme received two ‘T’ and three
‘D’ shares for each original Thistle Dubh Limited share held. The market values for the ‘T’ shares and the ‘D’
shares on the date of reorganisation were 135p and 405p per share respectively.
(iv) On 1 May 2005, Graeme sold 12,000 ‘T’ shares. The market values for the ‘T’ shares and the ‘D’ shares on that
day were 300p and 600p per share respectively.
(v) In October 2005, Graeme sold all of his ‘D’ shares for ￡85,000.
(vi) The current market value of ‘T’ shares is 384p per share. The shares remain unquoted.
Graeme and Catherine have owned a holiday cottage in a remote part of the UK for many years. In recent years, they
have used the property infrequently, as they have taken their holidays abroad and the cottage has been let out as
furnished holiday accommodation.
Graeme and Catherine are now considering selling the UK country cottage and purchasing a holiday villa abroad.
Initially they plan to let this villa out on a furnished basis, but following their anticipated retirement, would expect to
occupy the property for a significant part of the year themselves, possibly moving to live in the villa permanently.
Required:
(a) Calculate the total chargeable gains arising on Graeme’s disposals of ‘T’ and ‘D’ ordinary shares in May and
October 2005 respectively. (7 marks)
相似考题
更多“2 Graeme, aged 57, is married to Catherine, aged 58. They work as medical consultants, and both are higher ratetaxpayers. Barry, their son, is aged 32. Graeme, Catherine and Barry are all UK resident, ordinarily resident anddomiciled. Graeme has come to y”相关问题
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第1题：
3 Spica, one of the director shareholders of Acrux Ltd, has been in dispute with the other shareholders over plans to
expand the company’s activities overseas. In order to resolve the position it has been agreed that Spica will sell her
shares back to the company. Once the purchase of her shares has taken place, the company intends to establish a
number of branches overseas and acquire a shareholding in a number of companies that are resident and trade in
overseas countries.
The following information has been obtained from client files and meetings with the parties involved.
Acrux Ltd:
– An unquoted UK resident company.
– Share capital consists of 50,000 ordinary shares issued at ￡1·90 per share in July 2000.
– None of the other shareholders has any connection with Spica.
The purchase of own shares:
– The company will purchase all of Spica’s shares for ￡8 per share.
– The transaction will take place by the end of 2008.
Spica:
– Purchased 8,000 shares in Acrux Ltd for ￡2 per share on 30 September 2003.
– Has no income in the tax year 2008/09.
– Has chargeable capital gains in the tax year 2008/09 of ￡3,800.
– Has houses in the UK and the country of Solaris and divides her time between them.
Investment in non-UK resident companies:
– Acrux Ltd will acquire between 15% and 20% of each of the non-UK resident companies.
– The companies will not be controlled foreign companies as the rates of tax in the overseas countries will be
between 23% and 42%.
– There may or may not be a double tax treaty between the UK and the overseas countries in which the companies
are resident. Where there is a treaty, it will be based on the OECD model treaty.
– None of the countries concerned levy withholding tax on dividends paid to UK companies.
– The directors of Acrux Ltd are concerned that the rate of tax suffered on the profits of the overseas companies
will be very high as they will be taxed in both the overseas country and in the UK.
Required:
(a) (i) Prepare detailed calculations to determine the most beneficial tax treatment of the payment Spica will
receive for her shares; (7 marks)
正确答案：
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第2题：
A middle-aged man might want to see himself as a strong, attractive athlete, which means ().
A、All middle-aged men are in good physical health.
B、Men also hope to have a beautiful and strong appearance.
C、Men usually want to look as attractive as possible.
D、Older men should all get exercise in the gym.
参考答案：BC
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第3题：
Instagram, understood by young people, all the young people use Instagram in U.N., mainly aged 18－29 years old, of which men use Instagram more time than women。()此题为判断题(对，错)。
正确答案：错误
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第4题：
Catherine: Building a community without private cars
正确答案：A
解析：首先了解每个人的兴趣是什么，然后分析A-F六个主题，从而可以得出A：创建一种车的俱乐部，大家共用，这样会降低污染。B：用风涡轮机制造能源。 -
第5题：
I have decided to accompapy my aged mother this summer to visit France,which is one of her lifelong dreams.A:accommodate
B:take
C:escort
D:present答案：C解析：本句意思是：我已经决定今年夏天陪我上了年纪的母亲去法国，这是她一辈子的梦想之一二句中accompany意为“陪伴”，如：May we accompany you on your walk？我们陪你一起散步好吗？ 四个选项中accommodate意为“容纳”，如：It could accommodate at most approximately 25 percent of the total child population of eleven-plus．它只能容纳11岁以上的儿童总数的大约25%。 take意为“带走”。escort意为“陪同，护送”，如：I escorted him to the door.我陪他走到门口。present意为“介绍，出现”，如：The mayor presented him with a gold medal at an official city reception.市长在一次正式的市政招待会上给他颁发了一枚金质奖章。只有选项C 同句中画线单词含义接近。 -
第6题：
Prescription charges do not apply to the following people except（）
Aself-employed people
Bchild under 16
Cwar and armed forces disablement pensioners
Dwomen aged 60 and over and men aged 65 and over
A
略 -
第7题：
Which group of people cannot vote in the general election?（）
- A、Members in the House of Commons.
- B、Lords in the House of Lords.
- C、The UK citizens above the age of 18.
- D、The UK resident citizens of the Irish Republic.
正确答案:B -
第8题：
spark程序中由一个或多个以下哪个选项组成（）
- A、job
- B、driver
- C、age
- D、worker
正确答案:A -
第9题：
单选题Which group of people cannot vote in the general election?（）AMembers in the House of Commons.
BLords in the House of Lords.
CThe UK citizens above the age of 18.
DThe UK resident citizens of the Irish Republic.
正确答案： D解析： 暂无解析 -
第10题：
单选题He ______ it, but he used his experiences in his writing. He married Catherine Hogarth and they had a big family.Ahated
Benjoyed
Cwanted
Dshamed
正确答案： D解析：
根据下午的连词but表示转折，所以，可以判断他讨厌。故选A。 -
第11题：
单选题Which indefinite article a should be read emphatically in the following sentences?AHe is a handsome boy, but not smart.
BHe is not a suspect, he is the suspect.
CHe bought a cartoon book for his son.
DHe is talking with a middle-aged man.
正确答案： C解析： -
第12题：
单选题This aged patient complied with the physician’s orders, hoping for a quick recovery.Aobeyed
Bdefied
Cmemorized
Dcontemplated
正确答案： C解析：
句意：这位老病号按医嘱去做，希望自己早日康复。comply with的意思是“按……去做，遵守”，与obey同义。defy藐视；公然反抗。memorize记住，背。contemplate思考。 -
第13题：
(b) Provide the directors of Acrux Ltd with a detailed explanation of the maximum rate of tax that will be suffered
on both the distributed and non-distributed profits of the non-UK resident investee companies where:
(1) there is a double tax treaty between the UK and the country in which the individual companies are
resident; and
(2) there is no such double tax treaty.
Note: you are not required to explain the position of the overseas resident branches. (6 marks)
正确答案：
(b) Rate of tax on profits of non-UK resident investee companies
Undistributed profits
The companies will be subject to tax in the countries in which they are resident; this is because of their residency status or
because they have a permanent establishment in that country. Undistributed profits will not be taxed in the UK.
The rate of tax on undistributed profits will therefore be the rate of tax in the country of residency of the respective companies.
Distributed profits with double tax treaty
The dividends received by Acrux Ltd from each of the overseas companies will be grossed up in respect of underlying tax (the
overseas corporation tax paid on the distributed profits) because Acrux Ltd will own at least 10% of the overseas companies.
The gross amount will then be included in Acrux Ltd’s profits chargeable to corporation tax.
The treaty will provide double tax relief in the UK for the overseas tax suffered in respect of each dividend up to a maximum
of the UK tax on the grossed up overseas dividend. As a result of the double tax relief, the overall rate of tax suffered will be
the higher of the UK rate paid by Acrux Ltd and the overseas tax rate borne by the overseas company.
Where the rate of overseas tax in respect of a particular dividend exceeds the rate of corporation tax in the UK, excess foreign
tax will arise. This can be relieved, via onshore pooling, against the UK tax due on those dividends where the rate of tax in
the UK exceeds the rate overseas. This will reduce the overall rate of tax suffered on the total overseas profits of the overseas
companies as a whole.
Distributed profits with no double tax treaty
Where there is no double tax treaty, unilateral double tax relief will be available in the UK. This relief will operate in the same
way as double tax relief under a double tax treaty such that the overall rate of tax on each dividend will be the higher of the
UK rate paid by Acrux Ltd and the overseas rate borne by the overseas company. Relief via onshore pooling will also be
available. -
第14题：
some seats on the bus are ____ reserved for the aged and disabled.A. extraordinarily
B. intensively
C. extensively
D. exclusively
参考答案：D
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第15题：
_____ can be a volunteer.
A.Children B.Old women C.Anyone aged 12-70 D.Young people
正确答案：C
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第16题：
Which indefinite article "a" should be read emphatically in the following sentences
A.He is a handsome boy, but not smart.
B.He is not a suspect, he is the suspect.
C.He bought a cartoon book for his son.
D.He is talking with a middle-aged man.答案：B解析：考查虚词重读。本题要求找出不定冠词“a”在句中重读的情况。不定冠词属于虚词，通常情况下，虚词是不需要重读的，如果想表达一些强调的含义时，可以将所强调的虚词重读。A项强调的是形容词handsome．从第二个分句中的smart可以得知；B项的不定冠词“a”与后面的“the”形成对比，强调“他就是那个犯罪嫌疑人．而不是别人”，所以需要重读。C项和D项中的虚词没有表达任何特殊含义，所以不需要重读。故选B。 -
第17题：
Which group of people cannot vote in the general election?（）
AMembers in the House of Commons.
BLords in the House of Lords.
CThe UK citizens above the age of 18.
DThe UK resident citizens of the Irish Republic.
B
略 -
第18题：
一个或多个（）组成了spark程序
- A、job
- B、driver
- C、age
- D、worker
正确答案:A -
第19题：
Which file characteristic cannot be used in the Cisco IronPort Data Security policies？（）
- A、 file type
- B、 file size
- C、 file age
- D、 file name
正确答案:C -
第20题：
单选题The middle-aged man was seen _____ out of the house on the afternoon of the murder.Acame
Bcome
Cto come
Dhave come
正确答案： C解析：
句意：有人看见那个中年人在谋杀案发生的下午从房子里出来。sb. be seen to do sth. 固定用法，故为C。 -
第21题：
单选题What might prevent Mary, aged 25, becoming a babysitter?AShe once broke a traffic law and was fined.
BShe has never worked as a babysitter before.
CShe can’t speak Japanese very well.
正确答案： A解析：
分析推理题。由题句中的babysitter对应到第四个广告，发现该广告最重要的一个要求就是要有经验(experienced)，因此与经验有关的B项就是答案。 -
第22题：
单选题Prescription charges do not apply to the following people except（）Aself-employed people
Bchild under 16
Cwar and armed forces disablement pensioners
Dwomen aged 60 and over and men aged 65 and over
正确答案： D解析： 暂无解析 -
第23题：
单选题The sentence “In Kids Country we do not permit middle-aged” underlined in Paragraph 2 means that middle-aged .Aare not permitted to live in America
Bare not welcome in America
Cbecome old too quickly
Dhave already been overtaken by children
正确答案： C解析：
语义题。划线部分之前的内容指出“美国是孩子的王国，孩子是文明的中心”。结合下文提到的“三十岁被升格为五十岁，但三十岁的人知道他们的时代也会被取代”，可指划线部分指“中年人在美国不受欢迎”，因此选B。