(b) State the immediate tax implications of the proposed gift of the share portfolio to Avril and identify analternative strategy that would achieve Crusoe’s objectives whilst avoiding a possible tax liability in thefuture. State any deadline(s) in connec
题目
(b) State the immediate tax implications of the proposed gift of the share portfolio to Avril and identify an
alternative strategy that would achieve Crusoe’s objectives whilst avoiding a possible tax liability in the
future. State any deadline(s) in connection with your proposed strategy. (5 marks)
相似考题
参考答案和解析
(b) Gift of the share portfolio to Avril
Inheritance tax
The gift would be a potentially exempt transfer at market value. No inheritance tax would be due at the time of the gift.
Capital gains tax
The gift would be a disposal by Crusoe deemed to be made at market value for the purposes of capital gains tax. No gain
would arise as the deemed proceeds will equal Crusoe’s base cost of probate value.
Stamp duty
There is no stamp duty on a gift of shares for no consideration.
Strategy to avoid a possible tax liability in the future
Crusoe should enter into a deed of variation directing the administrators to transfer the shares to Avril rather than to him. This
will not be regarded as a gift by Crusoe. Instead, provided the deed states that it is intended to be effective for inheritance tax
purposes, it will be as if Noland had left the shares to Avril in a will.
This strategy is more tax efficient than Crusoe gifting the shares to Avril as such a gift would be a potentially exempt transfer
and inheritance tax may be due if Crusoe were to die within seven years.
The deed of variation must be entered into by 1 October 2009, i.e. within two years of the date of Noland’s death.
更多“(b) State the immediate tax implications of the proposed gift of the share portfolio to Avril and identify analternative strategy that would achieve Crusoe’s objectives whilst avoiding a possible tax liability in thefuture. State any deadline(s) in connec”相关问题
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第1题：
(b) Mabel has two objectives when making the gifts to Bruce and Padma:
(1) To pay no tax on any gift in her lifetime; and
(2) To reduce the eventual liability to inheritance tax on her death.
Advise Mabel which item to gift to Bruce and to Padma in order to satisfy her objectives. Give reasons for
your advice.
Your advice should include a computation of the inheritance tax saved as a result of the two gifts, on the
assumption that Mabel dies on 30 June 2011. (10 marks)
正确答案：
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第2题：
(c) (i) Compute Gloria’s capital gains tax liability for 2006/07 ignoring any claims or elections available to
reduce the liability. (3 marks)
正确答案：
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第3题：
(b) Calculate the inheritance tax (IHT) liability arising as a result of Christopher’s death. (11 marks)
正确答案：
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第4题：
(ii) Calculate Paul’s tax liability if he exercises the share options in Memphis plc and subsequently sells the
shares in Memphis plc immediately, as proposed, and show how he may reduce this tax liability.
(4 marks)
正确答案：
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第5题：
(iii) State the value added tax (VAT) and stamp duty (SD) issues arising as a result of inserting Bold plc as
a holding company and identify any planning actions that can be taken to defer or minimise these tax
costs. (4 marks)
You should 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.
正确答案：
(iii) Bold plc will be making a taxable supply of services, likely to exceed the VAT threshold. It should therefore consider
registering for VAT – either immediately on a voluntary basis, or when its cumulative taxable supplies in the previous
twelve months exceed ￡60,000.
As an alternative, the new group can apply for a group VAT registration. This will simplify its VAT administration as intragroup
transactions are broadly disregarded for VAT purposes, and only one VAT return is required for the group as a
whole.
Stamp duty normally applies at 0·5% on the consideration payable in respect of transactions in shares. However, an
exemption is available in the case of a takeover, reconstruction or amalgamation where there is no real change in
ownership, i.e. the new shareholdings mirror the old shareholdings, and the transaction is for commercial purposes. The
insertion of a new holding company over an existing company, as proposed here, would qualify for this exemption.
There is no VAT on transactions in shares. -
第6题：
(ii) Advise Andrew of the tax implications arising from the disposal of the 7% Government Stock, clearly
identifying the tax year in which any liability will arise and how it will be paid. (3 marks)
正确答案：
(ii) Government stock is an exempt asset for the purposes of capital gains tax, however, as Andrew’s holding has a nominal
value in excess of ￡5,000, a charge to income tax will arise under the accrued income scheme. This charge to income
tax will arise in 2005/06, being the tax year in which the next interest payment following disposal falls due (20 April
2005) and it will relate to the income accrued for the period 21 October 2004 to 14 March 2005 of ￡279 (145/182
x ￡350). As interest on Government Stock is paid gross (unless the holder applies to receive it net), the tax due of ￡112
(￡279 x 40%) will be collected via the self-assessment system and as the interest was an ongoing source of income
will be included within Andrew’s half yearly payments on account payable on 31 January and 31 July 2006. -
第7题：
(c) (i) Explain the inheritance tax (IHT) implications and benefits of Alvaro Pelorus varying the terms of his
father’s will such that part of Ray Pelorus’s estate is left to Vito and Sophie. State the date by which a
deed of variation would need to be made in order for it to be valid; (3 marks)
正确答案：
(c) (i) Variation of Ray’s will
The variation by Alvaro of Ray’s will, such that assets are left to Vito and Sophie, will not be regarded as a gift by Alvaro.
Instead, provided the deed states that it is intended to be effective for IHT purposes, it will be as if Ray had left the assets
to the children in his will.
This strategy, known as skipping a generation, will have no effect on the IHT due on Ray’s death but will reduce the
assets owned by Alvaro and thus his potential UK IHT liability. A deed of variation is more tax efficient than Alvaro
making gifts to the children as such gifts would be PETs and IHT may be due if Alvaro were to die within seven years.
The deed of variation must be entered into by 31 January 2009, i.e. within two years of the date of Ray’s death. -
第8题：
(b) Explain the corporation tax and value added tax (VAT) implications of the following aspects of the proposed
restructuring of the Rapier Ltd group.
(i) The immediate tax implications of the restructuring. (6 marks)
正确答案：
(b) The tax implications of the proposed restructuring of the Rapier Ltd group
(i) Immediate implications
Corporation tax
Rapier Ltd and its subsidiaries are in a capital gains group as Rapier Ltd owns at least 75% of the ordinary share capital
of each of the subsidiary companies. Any non-exempt items of plant and machinery owned by the subsidiaries will
therefore be transferred to Rapier Ltd at no gain, no loss.
No taxable credit or allowable debit will arise on the transfer of the subsidiaries’ goodwill to Rapier Ltd because the
companies are in a capital gains group.
The trading losses brought forward in Dirk Ltd will be transferred with the trade to Rapier Ltd as the effective ownership
of the three trades will not change (Rapier Ltd owns the subsidiaries which own the trades and, following the
restructuring, will own the three trades directly). The losses will be restricted to being offset against the future trading
profits of the Dirk trade only.
There will be no balancing adjustments in respect of the plant and machinery transferred to Rapier Ltd. Writing down
allowances will be claimed by the subsidiaries in respect of the year ending 30 June 2007 and by Rapier Ltd in respect
of future periods.
Value added tax (VAT)
No VAT should be charged on the sales of the businesses to Rapier Ltd as they are outside the scope of VAT. This is
because the trades are to be transferred as going concerns to a VAT registered person with no significant break in trading.
Switch Ltd must notify HM Revenue and Customs by 30 July 2007 that it has ceased to make taxable supplies. -
第9题：
(b) The directors of Carver Ltd are aware that some of the company’s shareholders want to realise the value in their
shares immediately. Accordingly, instead of investing in the office building or the share portfolio they are
considering two alternative strategies whereby, following the sale of the company’s business, a payment will be
made to the company’s shareholders.
(i) Liquidate the company. The payment by the liquidator would be ￡126 per share.
(ii) The payment of a dividend of ￡125 per share following which a liquidator will be appointed. The payment
by the liquidator to the shareholders would then be ￡1 per share.
The company originally issued 20,000 ￡1 ordinary shares at par value to 19 members of the Cutler family.
Following a number of gifts and inheritances there are now 41 shareholders, all of whom are family members.
The directors have asked you to attend a meeting to set out the tax implications of these two alternative strategies
for each of the two main groups of shareholders: adults with shareholdings of more than 500 shares and children
with shareholdings of 200 shares or less.
Required:
Prepare notes explaining:
– the amount chargeable to tax; and
– the rates of tax that will apply
in respect of each of the two strategies for each of the two groups of shareholders ready for your meeting
with the directors of Carver Ltd. You should assume that none of the shareholders will have any capital
losses either in the tax year 2007/08 or brought forward as at 5 April 2007. (10 marks)
Note:
You should assume that the rates and allowances for the tax year 2006/07 will continue to apply for the
foreseeable future.
正确答案：
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第10题：
5 Crusoe has contacted you following the death of his father, Noland. Crusoe has inherited the whole of his father’s
estate and is seeking advice on his father’s capital gains tax position and the payment of inheritance tax following his
death.
The following information has been extracted from client files and from telephone conversations with Crusoe.
Noland – personal information:
– Divorcee whose only other relatives are his sister, Avril, and two grandchildren.
– Died suddenly on 1 October 2007 without having made a will.
– Under the laws of intestacy, the whole of his estate passes to Crusoe.
Noland – income tax and capital gains tax:
– Has been a basic rate taxpayer since the tax year 2000/01.
– Sales of quoted shares resulted in:
– Chargeable gains of ￡7,100 and allowable losses of ￡17,800 in the tax year 2007/08.
– Chargeable gains of approximately ￡14,000 each tax year from 2000/01 to 2006/07.
– None of the shares were held for long enough to qualify for taper relief.
Noland – gifts made during lifetime:
– On 1 December 1999 Noland gave his house to Crusoe.
– Crusoe has allowed Noland to continue living in the house and has charged him rent of ￡120 per month
since 1 December 1999. The market rent for the house would be ￡740 per month.
– The house was worth ￡240,000 at the time of the gift and ￡310,000 on 1 October 2007.
– On 1 November 2004 Noland transferred quoted shares worth ￡232,000 to a discretionary trust for the benefit
of his grandchildren.
Noland – probate values of assets held at death: ￡
– Portfolio of quoted shares 370,000
Shares in Kurb Ltd 38,400
Chattels and cash 22,300
Domestic liabilities including income tax payable (1,900)
– It should be assumed that these values will not change for the foreseeable future.
Kurb Ltd:
– Unquoted trading company
– Noland purchased the shares on 1 December 2005.
Crusoe:
– Long-standing personal tax client of your firm.
– Married with two young children.
– Successful investment banker with very high net worth.
– Intends to gift the portfolio of quoted shares inherited from Noland to his aunt, Avril, who has very little personal
wealth.
Required:
(a) Prepare explanatory notes together with relevant supporting calculations in order to quantify the tax relief
potentially available in respect of Noland’s capital losses realised in 2007/08. (4 marks)
正确答案：
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第11题：
(ii) State, with reasons, whether Messier Ltd can provide Galileo with accommodation in the UK without
giving rise to a UK income tax liability. (2 marks)
正确答案：
(ii) Tax-free accommodation
It is not possible for Messier Ltd to provide Galileo with tax-free accommodation. The provision of accommodation by an
employer to an employee will give rise to a taxable benefit unless it is:
– necessary for the proper performance of the employee’s duties, e.g. a caretaker; or
– for the better performance of the employee’s duties and customary, e.g. a hotel manager; or
– part of arrangements arising out of threats to the employee’s security, e.g. a government minister.
As a manager of Messier Ltd Galileo is unable to satisfy any of the above conditions. -
第12题：
Text 4 The EU's faltering progress towards a common system of taxing the huge revenues of the new digital giants lurched forward this morning as Margrethe Vestager,the EU commissioner in charge of competition,declared that Amazon had received unfair state aid from Luxembourg through its tax arrangements,and demanded that it pay￡250m in back taxes.At the same time,Ms Vestager announced that the European commission would haul Ireland up before the European court of justice for its failure to demand￡13bn of unpaid tax from Apple,identi{ied in an earlier investigation.The lwo events illusrrate the gulf between the commission,together with some of the EU's iargest economies,and smaller members such as Ireland and Luxembourg.Both Ireland and Luxembourg defend their tax arrangements.Ireland in particular welcomes the thousands of goocl jobs that the tech giants bring and has no desire to find ways of extracting more tax from thcm in case it drives them away.The Irish government also insists that taxation is a sovereign matter,not an arena for EU interference.（ ）thers are under pressure from voters who are outraged that any company can make so much profit in their country and pay so little tax on it.Revenue from Facebook's UK operations,it has emerged,nearly quadrupled last year t0 842m,through growth in digital ad sales;its corporation tax bill crept up from 4.2m t0 5.Im.The US inland revenue service is also keen to find transparent ways of taxing the new digital economy,and is watching jealously as the European commission draws up its plans,suspicious of any move that might be used by the tech giants to offset their US tax bills.Already,companies such as Google and Amazon hold billions of dollars in offshore funds,where ihey are out of reach of the taxman.The US defensiveness about its own tax revenues points to the need for a global rather than a merely European solution to the question of how,what and whcre to tax the digital economy,but progress through the Organization for Economic Co-operation and Development（OECD）is glacial,and would in any event only be advisory.The commission is still hoping to get agreement on a common corporate tax base that would help to identify the parameters of any new tax system,but progress has stalled because of complexities around double taxation.Meanwhile the American Chamber of Commerce in Europe（ACCE）is warning that any attempt to tax the tech giants more would threaten investment and expansion.But across most of the EU discontent is growing,not just over the failure to pay tax-which has already prompted some tech companies to become more transparent,and even pay more-but over many of their practices.The chief executive of the ride-hailing app Uber has been in London this week trying to patch up relations with Transport for London（TfL）.Margrethe Vestager is right:enforcing regulations works.
The U.S.'s close attention to EU's tax plan making is mentioned to stress_____A.the OECD's failure to fulfill its obligation
B.Google and Amazon's success outside the U.S.
C.U.S.'s jealousy in European progress in tax reform
D.the universality of digital economy taxation problem答案：D解析：[信息锁定]题干内容位于第四段首句，②③句随后指出，谷歌和亚马逊的海外资金已高达数十亿美元，却不受税收管制（out of reach“the taxman）；美国对自己税收可能流失的忧虑表明，像科技巨头征税的难题不止存在于欧洲．而是个全球性亟待解决的问题，D.符合文中用意。[解题技巧]A.源于段末“作者对OECD在推进全球性税改问题上未能发挥应有作用的不满”．但这里在补充全球性改革没有进展的原因，并非提及美国关注欧盟改革的目的。B.局限于例子本身内容而忽略上下文语义。C.把首句中watching jealously at.…（小心密切关注欧盟举动，考虑自身疏漏）偷换为简单的嫉妒之情，其次欧盟在税改问题上进展不尽人意，嫉妒无从谈起。注意此处jealously意为“戒备地，留心提防地”。 -
第13题：
(b) Compute Gloria’s total income tax and national insurance liability for 2006/07. (7 marks)
正确答案：
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第14题：
(d) Explain how Gloria would be taxed in the UK on the dividends paid by Bubble Inc and the capital gains tax
and inheritance tax implications of a future disposal of the shares. Clearly state, giving reasons, whether or
not the payment made to Eric is allowable for capital gains tax purposes. (9 marks)
You should assume that the rates and allowances for the tax year 2005/06 apply throughout this question.
正确答案：
(d) UK tax implications of shares in Bubble Inc
Income tax
Gloria is UK resident and is therefore subject to income tax on her worldwide income. However, because she is non-UK
domiciled, she will only be taxed on the foreign dividends she brings into the UK.
Dividends brought into the UK will be grossed up for any tax paid in Oceania. The gross amount is taxed at 10% if it falls
into the starting or basic rate band and at 321/2% if it falls into the higher rate band. The tax suffered in Oceania is available
for offset against the UK tax liability. The offset is restricted to a maximum of the UK tax on the dividend income.
Capital gains tax
Individuals are subject to capital gains tax on worldwide assets if they are resident or ordinarily resident in the UK. However,
because Gloria is non-UK domiciled and the shares are situated abroad, the gain is only taxable to the extent that the sales
proceeds are brought into the UK. Any tax suffered in Oceania in respect of the gain is available for offset against the UK
capital gains tax liability arising on the shares.
Any loss arising on the disposal of the shares would not be available for relief in the UK.
In computing a capital gain or allowable loss, a deduction is available for the incidental costs of acquisition. However, to be
allowable, such costs must be incurred wholly and exclusively for the purposes of acquiring the asset. The fee paid to Eric
related to general investment advice and not to the acquisition of the shares and therefore, would not be deductible in
computing the gain.
Taper relief will be at non-business asset rates as Bubble Inc is an investment company.
Inheritance tax
Assets situated abroad owned by non-UK domiciled individuals are excluded property for the purposes of inheritance tax.
However, Gloria will be deemed to be UK domiciled (for the purposes of inheritance tax only) if she has been resident in the
UK for 17 out of the 20 tax years ending with the year in which the disposal occurs.
Gloria has been running a business in the UK since June 1992 and would therefore, appear to have been resident for at least
15 tax years (1992/93 to 2006/07 inclusive).
If Gloria is deemed to be UK domiciled such that the shares in Bubble Inc are not excluded property, business property relief
will not be available because Bubble Inc is an investment company. -
第15题：
(b) (i) State the condition that would need to be satisfied for the exercise of Paul’s share options in Memphis
plc to be exempt from income tax and the tax implications if this condition is not satisfied.
(2 marks)
正确答案：
(b) (i) Paul has options in an HMRC approved share scheme. Under such schemes, no tax liabilities arise either on the grant
or exercise of the option. The excess of the proceeds over the price paid for the shares (the exercise price) is charged to
capital gains tax on their disposal.
However, in order to secure this treatment, one of the conditions to be satisfied is that the options cannot be exercised
within three years of the date of grant. If Paul were to exercise his options now (i.e. before the third anniversary of the
grant), the exercise would instead be treated as an unapproved exercise. At that date, income tax would be charged on
the difference between the market value of the shares on exercise and the price paid to exercise the option. -
第16题：
(c) For commercial reasons, Damian believes that it would be sensible to place a new holding company, Bold plc,
over the existing company, Linden Limited. Bold plc would also be unquoted and would acquire the existing
Linden Limited shares in exchange for the issue of its own shares.
If the new structure is implemented, Bold plc will provide management services to Linden Limited, but the
amount that will be charged for these services is yet to be determined.
Required:
(i) State the capital gains tax (CGT) issues that Damian should be aware of before disposing of his shares
in Linden Limited to Bold plc. Your answer should include details of any conditions that will need to be
satisfied if an immediate charge to tax is to be avoided. (4 marks)
正确答案：
(c) (i) The proposed transaction broadly falls under the ‘paper for paper’ rules. Where this is the case, chargeable gains do not
arise. Instead, the new holding stands in the shoes (and inherits the base cost) of the original holding.
The company issuing the new shares must:
(i) end up with more than 25% of the ordinary share capital or a majority of the voting power of the old company,
OR
(ii) make a general offer to shareholders in the old company with a condition which would give the acquiring company
control of the company if accepted.
The exchange must be for bona fide commercial reasons and not have as its main purpose (or one of its main purposes)
the avoidance of capital gains tax or corporation tax.
The issue of shares by Bold plc satisfies these conditions, thus Damian, as a shareholder of Linden Limited, will not be
taxed on the exchange of shares. -
第17题：
(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.
正确答案：(b) [Ben’s address] [Firm’s address]
Dear Ben [Date]
A company purchase of own shares can be subject to capital gains treatment if certain conditions are satisfied. However, one
of these conditions is that the shares in question must have been held for a minimum period of five years. As at 1 May 2010,
your shares in Flower Limited have only been held for four years and ten months. As a result, the capital gains treatment will
not apply.
In the absence of capital gains treatment, the position on a company repurchase of its own shares is that the payment will
be treated as an income distribution (i.e. a dividend) in the hands of the recipient. The distribution element is calculated as
the proceeds received for the shares less the price paid for them. On the basis that the purchase price is ￡500,000, then the
element of distribution will be ￡499,500 (500,000 – 500). This would be taxed as follows:
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第18题：
(b) Calculate Alvaro Pelorus’s capital gains tax liability for the tax year 2006/07 on the assumption that all
available reliefs are claimed. (8 marks)
正确答案：
-
第19题：
(ii) Advise Mr Fencer of the income tax implications of the proposed financing arrangements. (2 marks)
正确答案：
(ii) The income tax implications of the proposed financing arrangements
Mr Fencer has borrowed money from a UK bank in order to make a loan to Rapier Ltd, a close company. The interest
paid by Mr Fencer to the bank will be an allowable charge on income as long as he continues to hold more than 5% of
Rapier Ltd. Charges on income are deductible in arriving at an individual’s statutory total income.
Mr Fencer will receive interest from Rapier Ltd net of 20% income tax. The gross amount of interest will be subject to
income tax at either 10%, 20% or 40% depending on whether the income falls into Mr Fencer’s starting rate, basic rate
or higher rate tax band. Mr Fencer will obtain a tax credit for the 20% income tax suffered at source. -
第20题：
(ii) Any increase or decrease in the group’s budgeted corporation tax liability for the year ending 30 June
2008 due to the restructuring on the assumption that trading losses will be used as efficiently as
possible. (8 marks)
正确答案：(ii) The budgeted corporation tax liability for the year ending 30 June 2008
Following the proposed restructuring, Rapier Ltd will be carrying on four separate trades. The current year loss arising
in the Dirk trade can be offset against its total profits. Its three subsidiaries will be dormant and will not be associates
for the purpose of determining the rate of corporation tax.
-
第21题：
(b) (i) Explain, by reference to Coral’s residence, ordinary residence and domicile position, how the rental
income arising in respect of the property in the country of Kalania will be taxed in the UK in the tax year
2007/08. State the strategy that Coral should adopt in order to minimise the total income tax suffered
on the rental income. (7 marks)
正确答案：
(b) (i) UK tax on the rental income
Coral is UK resident in 2007/08 because she is present in the UK for more than 182 days. Accordingly, she will be
subject to UK income tax on her Kalanian rental income.
Coral is ordinarily resident in the UK in 2007/08 as she is habitually resident in the UK.
Coral will have acquired a domicile of origin in Kalania from her father. She has not acquired a domicile of choice in the
UK as she has not severed her ties with Kalania and does not intend to make her permanent home in the UK.
Accordingly, the rental income will be taxed in the UK on the remittance basis.
Any rental income remitted to the UK will fall into the basic rate band and will be subject to income tax at 22% on the
gross amount (before deduction of Kalanian tax). Unilateral double tax relief will be available in respect of the 8% tax
suffered in Kalania such that the effective rate of tax suffered by Coral in the UK on the grossed up amount of income
remitted will be 14%.
In order to minimise the total income tax suffered on the rental income Coral should ensure that it is not brought into or
used in the UK such that it will not be subject to income tax in the UK.
Coral should retain evidence, for example bank statements, to show that the rental income has not been removed from
Kalania. Coral can use the money whilst she is on holiday in Kalania with no UK tax implications. -
第22题：
(ii) Explain why Galileo is able to pay the inheritance tax due in instalments, state when the instalments are
due and identify any further issues relevant to Galileo relating to the payments. (3 marks)
正确答案：
(ii) Payment by instalments
The inheritance tax can be paid by instalments because Messier Ltd is an unquoted company controlled by Kepler at
the time of the gift and is still unquoted at the time of his death.
The tax is due in ten equal annual instalments starting on 30 November 2008.
Interest will be charged on any instalments paid late; otherwise the instalments will be interest free because Messier is
a trading company that does not deal in property or financial assets.
All of the outstanding inheritance tax will become payable if Galileo sells the shares in Messier Ltd.
Tutorial note
Candidates were also given credit for stating that payment by instalments is available because the shares represent at
least 10% of the company’s share capital and are valued at ￡20,000 or more. -
第23题：
(c) (i) Calculate Benny’s capital gains tax liability for 2006/07. (6 marks)
正确答案：